General Privacy Notice Privacy Notice for California Residents

Open Road Intermediate Holdings, LLC Privacy Policy

Last Update: 01/02/2020

Introduction - Your Relationship with the Open Road Intermediate Holdings Marketplaces
Information You Share With Us
Additional Information We Receive About You
How We Use, Share, or Disclose Information
Managing Your Personal Information with Us
Children and Our Services
Residents of the State of California
Residents of the European Union
Changes to This Privacy Policy

Introduction - Your Relationship with the Open Road Intermediate Holdings Marketplaces

We believe you should always know what data we collect from you and how we use it, and that you should have meaningful control over both. We want to empower you to make the best decisions about the information that you share with us. That's the purpose of this Privacy Policy. You should read this policy in full, but here are several key things we hope you take away from it:

Open Road Intermediate Holdings, LLC ("Open Road", "we", or "us") owns and operates a set of specialty marketplaces that connect buyers, sellers, owners of recreational vehicles, motorcycles, boats and vehicles. The purpose of our marketplaces is to share the information you provide as an interested buyer or renter with those specific third-party sellers or owners you identify.
Open Road receives no finder's fee, revenue share, or other monetary compensation for connecting you to the seller or owner of the item you are interested in.
You don't have to provide any information about yourself to search the marketplaces, check the prices of different vehicles, explore the inventory a specific seller or owner is offering, or otherwise browse our marketplaces.
When you use Open Road's websites, even if you simply search our marketplaces, we receive some personal information from you such as the type of device you're using and your IP address. We also use tracking data during your active session on our marketplaces so you can move around the site and go back to previously visited information without losing that information.
You can choose to share additional information with us, including your email address, phone number, mailing address, or phone number. You do this by completing an online interest form so we can connect you with a seller or owner. You will also provide certain personal information when you create an account to join our community of recreational vehicle enthusiasts or save your searches for future use.
After you have been connected with a seller or owner regarding your interest, any subsequent personal information or additional information you share directly with a seller or owner via any method is not covered by this privacy policy.
As a seller or owner advertising on our marketplaces or listing inventory for sale, you are a third-party business customer of Open Road. Your use and participation in our marketplaces will be governed by your contract with Open Road as well as by other separate terms, conditions, and agreements as posted at the bottom of each marketplace page. As a business customer, you will provide Open Road with detailed information on your business and your inventory. You will also designate employees as key contacts (and provide their detailed contact information) for your Open Road relationship. All information you provide to Open Road should be tied to your business or dealership – please don't provide any personal contact information or data as part of our business relationship.
If you buy an ad on our marketplaces to sell, you will be required to provide certain personal information to Open Road to complete the transaction, as well as to protect both you and potential buyers from fraud. This additional personal information may include payment data (such as credit card information) or detailed information about you including your driver's license, vehicle information, location or vehicle, or proof of ownership. As disclosed in more detail below, we use third-party processing to manage and protect this sensitive personal information. We do not obtain, store, or tie this additional personal data to your Open Road account or marketplace activity nor does this information get shared in detail with the sellers or owners.
You have the ability to adjust your browser settings to manage how we or other websites track your browsing activity. More information can be found at StaySafeOnline.org. Additionally, you can manage the advertising presented to you while browsing any website through the Ad Choices link at the bottom of each page in our marketplaces.
If you have questions about this policy, how we collect or process your personal data, or anything else related to our privacy practices, we want to hear from you. You can contact us at any time at our Contact Us page or by email at privacysupport@cycleinsider.com.
If you do not agree with our privacy policies and practices as outlined below, your choice is not to use our marketplaces to connect you with sellers and owners. For some marketplaces, you may call sellers or owners directly or visit them in person – we would appreciate your letting them know you found them through Open Road.

This policy covers the following marketplaces underneath the Open Road umbrella. Some are used to connect buyers and renters with sellers or owners, and others are used exclusively by our sellers and owners to manage their company information, manage their employee access to their online information, and/or to update/change inventory and listings.

RVInsider.com
CycleInsider.com

This policy applies to information we collect from or about you through our marketplaces and in email between you and a marketplace. Additionally, we may retain records of our communications through other media (such as phone and mail) based on questions or inquiries you provide.

Information You Share With Us

We require certain information to provide our services to you, whether you are a buyer or seller. For example, you must have an account with us in order to list a vehicle for sale. When you choose to share the information below with us, we collect and use this information to operate our marketplaces and to connect you with buyers or sellers.

Guest Searching to Basic Request and Account Information: You don't have to create an account to use some of our marketplace features, such as searching for vehicles, looking at seller or owner inventory, or checking out the prices of vehicles listed for sale. If you choose to receive our newsletters, create an account on our marketplaces, participate in sweepstakes/give-a-ways, or engage in other other marketplace activities, you must provide us with some personal data so we can enroll you in those services or set-up your account. Each contact form, interest form, account set-up, or reservation request identifies the required personal data fields to be completed prior to submitting it to us. Additional fields may be shown but are not required to complete your submission.

When you register for a newsletter, enter a sweepstakes, or set up an account, we may ask for your email address and/or your first name and last name. If you ask to be connected to a seller, we ask you to provide, in addition to the above, additional contact information such as your phone number and physical address.

Public Information - Customer Reviews: Some of our marketplaces include the ability for buyers to provide reviews or comments on sellers of vehicles. Your comments and reviews are posted publicly on our marketplace. Prior to posting your review or comments, we will assess your posting to ensure it meets our content standards and is not inappropriate, offensive, or discriminatory.

If you would like to have your posted customer review removed from a marketplace, please send us a request through our Contact Us page. Please provide sufficient information to help us to identify the Customer Review that you wish to have removed. We may contact you if we require additional evidence to verify that you are the author of the review. Please note, even if we delete your Customer Review from the marketplace, copies of your review may remain viewable in cached and archived pages, or might have been copied or saved by other users.

Social Media Accounts: You may choose to follow Open Road or our marketplaces via provided links to Facebook, Twitter, Pinterest, or Instagram. We will have visibility into the connection information you share via these social media platforms. You may also choose to use your Facebook or Google accounts to sign-in and create a user account. These social or sign-in connections with our marketplaces may automatically provide us with access to certain personal data they have stored about you (such as content you have viewed or enjoyed, information about the advertisements you have been shown or clicked on, etc.). You can determine the personal data that we can access through the privacy settings available through your account with these companies.

Payment Information: Open Road does not process payments for any parties on our marketplaces. When you are ready to pay for a listing to sell a vehicle or other payment transactions allowed via our marketplaces, your payment will be completed by a third-party payment processing company, Braintree, PayPal or Stripe. Braintree, PayPal or Stripe will accept and store your payment information, process your payment transaction, and provide confirmation back to you, the owner, and us as applicable that your payment has completed successfully.

Other Data You May Share with Our Company: In addition to your interaction with our marketplaces, you may share information about yourself and your interests through:

Information you provide when you apply for a job through our website. This includes any email address you provide to receive a reminder to apply for a position via "Remind me to apply later".
Information that you provide by completing and submitting "help" inquiries. This includes requesting specific services or support that may be tied to an account or other relationship you have with our marketplaces.
Records and copies of your correspondence (including email addresses), if you contact us, including through the "Contact" or "Send Us Feedback" page of our marketplaces.
Information you share in the free-from text box on our email inquiry form that could include additional personal data we did not specifically request from you. Other information you provide in that text box that could be used to associate you to an existing account or other relationship with our company or marketplaces.

How You Control Information You Provide to Us:

As noted above, you control how and what you share with our marketplaces. Below are actions you can take:

Only share your information when you want to be connected to a seller, and be contacted on a vehicle. You can search and look without providing any information or identifying yourself.
If you have an account, you can update and change the information associated with your account via our marketplaces. The account information clearly shows what information is required to maintain your account. It is your choice to enter additional information on optional fields.
Account holders may also send us an email at privacysupport@cycleinsider.com to request access to correct or delete any personal information that you have provided to us. Some of your personal information cannot be deleted by us except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Additional Information We Receive About You

We receive certain information when you use our services or other marketplaces or mobile applications that include our content, and from third parties including advertisers. We use such data, described in detail below, to operate our marketplaces.

Location Information: We require information about current location, which we get from signals such as your IP address or device settings, to determine content and services available to you through our marketplaces. We use an outside vendor company to resolve your IP address during a browsing session to a location. We do not retain your IP address as part of your activity or account.

Links: In order to operate our marketplaces, we keep track of how you interact with links across our services. If you click on an external link or ad on our marketplaces, that advertiser or website operator might figure out that you came from our site, along with other information associated with the ad you clicked, such as characteristics of the audience it was intended to reach. They may also collect other personal data from you, such as cookie identifiers or your IP address.

Additionally, our marketplaces may contain links to other websites not affiliated with Open Road, including web sites of our vehicle dealers, manufacturers, third-party vendors, and service providers. We are not responsible for their privacy practices or the content of their websites. By including links to other websites or services, we neither endorse such websites nor guarantee that the information they contain is accurate. We encourage you to be aware when you leave our site and to read the privacy policies of every linked website as the privacy policies of each may differ from ours. This Privacy Policy applies solely to Open Road and its marketplaces.

Cookies, Web Beacons, and Similar Technology: A cookie is a small piece of data that is stored on your computer or mobile device. Similar to many websites, we use cookies, web beacons and similar technologies to collect additional website usage data, store and read data files on your computer, and to operate our marketplaces. This is typically done to maintain your preferences or to improve speed and performance by storing certain files locally. However, these technologies can also store a unique identifier for your computer, which can be used to track behavior.

Cookies are not required for many parts of our marketplaces, such as searching. Although most web browsers automatically accept cookies, many browsers' settings can be set to decline cookies or alert you when a website is attempting to place a cookie on your computer. However, some of our services may not function properly if you disable cookies. When your browser or device allows it, we use both session cookies and persistent cookies to better understand how you interact with our marketplaces, to monitor aggregate usage patterns, and to personalize and otherwise operate our services such as by providing account security and personalizing the content we show you including ads. We do not support the Do Not Track browser option.

Cookie Settings

Log Data: We receive information when you view content on or otherwise interact with our marketplaces, which we refer to as "Log Data," even if you have not created an account. For example, when you visit our marketplaces, sign into your account, or interact with our email or contact forms, we may receive information about you. This Log Data includes information about your computer and internet connection, as well as details of your visit to our marketplaces. Specifically, this includes traffic data, logs, and other communication data and the resources that you accessed and used – some data may only be used during your active session (and then forgotten) while other data may persist such as your preferences or remembering you when you return. We may include IP address, browser type, operating system, the referring web page, pages visited, location (based on IP address), device information (including device and application IDs), search terms, and cookie information.

We use Log Data to operate our services and ensure their secure, reliable, and robust performance. For example, we use Log Data to protect the security of accounts and to determine what content is popular on our marketplaces. We also use this data to improve the content we show you, including ads. We use the information you provide to us and data we receive, including Log Data and data from third parties, to make inferences like what topics you may be interested in which helps us better design our services for you and personalize the content we show you, including ads.

Advertisers and Other Ad Vendors: Advertising revenue allows us to support and improve our marketplaces. We use the information we collect as described in this Privacy Policy to help make our advertising more relevant to you. Our advertisers, ad vendors and affiliates share information with us such as browser cookie IDs, mobile device IDs, hashed email addresses, demographic or interest data, and content viewed or actions taken on a website or app. Some of our advertisers and ad vendors also enable us to collect similar information directly from their website or app by integrating our advertising technology. Open Road adheres to the Digital Advertising Alliance Self-Regulatory Principles for Online Behavioral Advertising (also referred to as "interest-based advertising") and respects the DAA's consumer choice tool for you to opt out of interest-based advertising. Learn more about your privacy options for interest-based ads.

Other Third Parties and Affiliates: We may receive information about you from third parties who are not our advertisers or ad vendors, such as vendors and service providers who help us evaluate the safety and quality of content on our platform or our corporate affiliates.

Personalizing Across Your Devices: When you log into our marketplaces on a browser or via our mobile application on a device, we will associate that browser or device with your account for purposes such as authentication, security, and personalization. We may also associate the activity you did on one and share it with the other. We do this to operate and personalize our marketplaces and make them more relevant to you.

How We Use, Share, or Disclose Information

The nature of our marketplaces require that we share your personal information directly with the seller or owner you have identified in your interest/contact form to make these connections. You play a large part in what personal data we share and with whom we share it. However, in limited circumstances we may also disclose your personal data for additional purposes. We make such disclosures either (a) at your direction, (b) subject to your right to opt-out, (c) as necessary to operate our services, or (d) as required by law.

Sharing You Control: We share or disclose your personal data with your consent or at your direction to connect you with the designated seller or owner that has the vehicle or equipment you are interested in.

Subject to your settings, we also provide certain third parties with personal data to help us offer or operate our services. For example, we share with advertisers the identifiers of devices that saw their ads, to enable them to measure the effectiveness of our advertising business. You can learn more about these partnerships in our Help Center, and you can control whether we share your personal data in this way by using the "Share your data with Open Road business partners" settings. Note that this setting does not control sharing described elsewhere in our Privacy Policy, such as when we share data with our service providers. The information we share with these partners does not include your name, email address, phone number, or any marketplace account information.

Service Providers: We engage service providers to perform functions and provide services to us in the United States. For example, we use third-party services such as Google Analytics to help operate our marketplaces, such as hosting our content, creating rental reservations, and to help us understand the use of our services. We may share your personal data with such service providers subject to obligations consistent with this Privacy Policy and any other appropriate confidentiality and security measures. We also share data with service providers only on the condition that the third parties use your private personal data only on our behalf and pursuant to our instructions. Third parties are prohibited from further sharing or selling any of the personal data we provide to them.

While we don't accept and process your payments, we facilitate the connection to our third party payment processing providers, Clear Commerce and Stripe, to accept your payment data, store that data as needed, process your payment transaction, and manage any post-transaction activities. Clear Commerce and Stripe may send us information that the charge failed or was otherwise fraudulent, or that there is a dispute on a charge made on our behalf. We may share additional data with Clear Commerce or Stripe to investigate and resolve activities resulting from the payment process.

Law, Harm, and the Public Interest: Notwithstanding anything to the contrary in this Privacy Policy or controls we may otherwise offer to you, we may preserve, use, or disclose your personal data if we believe that it is reasonably necessary to:

Comply with a law, regulation, legal process, or governmental request;
Protect the safety of any person;
Protect the safety or integrity of our platform, including to help prevent spam, abuse, or malicious actors on our services, or to explain why we have removed content or accounts from our services;
Address fraud, security, or technical issues; or
Protect our rights or property or the rights or property of those who use our services.

However, nothing in this Privacy Policy is intended to limit any legal defenses or objections that you may have to a third party's, including a government's, request to disclose your personal data.

Affiliates and Change of Ownership: In the event we are involved in a bankruptcy, merger, acquisition, reorganization, or sale of assets, your personal data may be sold or transferred as part of that transaction. This Privacy Policy will apply to your personal data as transferred to the new entity. We may also disclose personal data about you to our corporate affiliates in order to help operate our services and our affiliates' services, including the delivery of ads.

Non-Personal Information: We collect, share and/or disclose non-personal data, such as anonymized or "de-identified" information and aggregated information about our customers and marketplace users such as the total number of times people engaged our marketplaces this month, the states those visits came from, or information related to advertising clicks or other metrics. This information does not identify any individual, without exception. All such non-personally identifiable information collected by us through our marketplaces, and all aggregated/compilations of non-personally identifiable information that we create, are the exclusive property of Open Road. We may use any such non-personally identifiable or aggregated information for any purpose, including monitoring user traffic patterns, analyzing and quantifying user preferences, improving the design and content of our Services, and enabling us to personalize your user experience, and we may share it with customers, advertisers, service providers, and other third parties.

Other Uses: Open Road also uses information collected about you, as well as non-personal data, to provide and improve our services and products, including to:

provide and deliver our products and services, assist with processing transactions and send related information such as confirmations and invoices;
send you technical notices, updates, security alerts and support and administrative messages;
communicate with you about products, services, offers, promotions, rewards and events offered by Open Road and others, and provide news and information we think will be of interest to you;
monitor and analyze trends, usage and activities in connection with our products and services;
revise, modify, and update existing services and products and develop new services and products;
personalize the services and products and present you with advertising, content or features that we believe will be of interest or useful to you; and
carry out any other purpose described to you at the time immediately before the information was collected.

Storage of Information and Data: Open Road Intermediate Holdings, LLC is located in the United States. All server information that we receive or collect is stored in the United States and governed by United States law.

Managing Your Personal Information with Us

You control the personal data you share with us and that we forward onto the respective seller or owner. You may use a contact form to have us connect you with a specific seller who has the vehicle or equipment you are looking for. You may submit a rental reservation request for an owner's specific recreational vehicle for your next vacation. While it is more likely you will communicate directly with the seller or owner, you can ask us to provide access to or to correct the data you have provided.

If you have created an account, you can update the account information or delete your account. Where applicable, we also provide you tools to restrict or withdraw consent for contacting you or the use of data you have provided to us. We make the data you shared available in our marketplaces portable and provide easy ways for you to contact us.

Accessing or Rectifying Your Personal Data: If you have submitted a contact or interest form that we shared with the designated seller or owner, you can obtain a copy of what we sent by filling out this Web Form directly. We may include, as part of your contact or interest form submission, other information that is inferred from your visit or passively obtained via third-parties about you and your activity. This additional information is only included along with the contact information you provided to businesses that sell vehicles.

If you have created an account on Open Road marketplaces, we provide you with tools and account settings to access, correct, delete, or modify the personal data you provided to us and associated with your account.

Deletion: We keep Log Data for a maximum of 18 months. If you follow the instructions here, your account will be deactivated and then deleted. When deactivated, your account will no longer be viewable on our marketplaces. For up to 30 days after deactivation, it is still possible to restore your account if it was accidentally or wrongfully deactivated.

Object, Restrict, or Withdraw Consent: When you are logged into your account, you can manage your settings and other account features here at any time.

Portability: Open Road can provide you a means to request a download or the information you have shared through our marketplaces by filling out the form Here.

Additional Information or Assistance: Thoughts or questions about this Privacy Policy? Please let us know by emailing us at privacysupport@cycleinsider.com or writing to us at the appropriate address below.

If you live in the United States or Canada, the data controller responsible for your personal data can be contacted at:

Open Road Intermediate Holdings, LLC
P.O. Box 14332
Mill Creek, WA, 98082
USA

If you live outside the United States or Canada please reference the Residents of the European Union section below

Children and Our Services

Our marketplaces assume all users expressing interest in purchasing from our sellers and owners are of majority age, can sign a contract, have a payment form issued in their name, and have a valid driver's license. Our services are not directed to children, and you may not use our services if you are under the age of 18. You must also be old enough to consent to the processing of your personal data in your country or state of residence.

Residents of the State of California

If you are a resident of the State of California, you may have additional privacy rights under the California Consumer Privacy Act. Learn more about these privacy rights by visiting our Privacy Notice for California Residents.

Residents of the European Union

Currently the Open Road marketplaces are not open for use by residents of the European Union. We block IP addresses that trace back to locations within the European Union or European Economic Area. If you are a resident of the EU and have accessed our marketplace from inside the United States, you may search our marketplaces, create an account (tied to a non-European Union identity), or make connections with sellers and renters on our marketplace. However, your transaction or interaction may be denied or blocked if you provide personal information that identifies you as a resident of the European Union.

Changes to This Privacy Policy

We may revise this Privacy Policy from time to time. The most current version of the policy will govern our processing of your personal data and will always be at https://www.cycleinsider.com/privacy. If we make a change to this policy that, in our sole discretion, is significant, we will notify you via an email to the email address associated with your account. By continuing to access or use our marketplaces after those changes become effective, you agree to be bound by the revised Privacy Policy.

Effective: January 1, 2020

Your Privacy Rights as a California Resident - California Consumer Privacy Act

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Policy of Open Road Intermediate Holdings, LLC ("Open Road") and applies solely to visitors and users that are residents of the State of California. We adopt this notice to comply with the California Consumer Privacy Act of 2018, as amended ("CCPA"), and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect
How We Obtain Information We Collect
Use of Personal Information
Sharing Personal Information
Your Rights and Choices
Access to Specific Information and Data Portability Rights
Deletion Request Rights
Exercising Access, Data Portability, and Deletion Rights
Response Timing and Format
Non-Discrimination
Changes to Our Privacy Notice
Contact Information

Last Update: 1/1/2020

Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household ("personal information"). In particular, we have collected the following categories of personal information from consumers 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 (physical illness, mental illness or disabilities). 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).	YES
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.	YES
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.	YES
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.	Profiles reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	NO

Personal information does not include:

Publicly available information from government records.
De-identified or aggregated consumer information.
Information excluded from the CCPA's scope, such as:
- Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; or
- Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

How We Obtain Information We Collect

We obtain the categories of personal information listed above from the following categories of sources:

Directly from consumers. For example, from email provided on our marketplaces for consumers to obtain our newsletters, enter sweepstakes or giveaways, to be connected with a seller or owner, or other participation in our marketplace communities.
Directly from seller and owners. For example, information that sellers and owners provide to list vehicles for sale on our marketplaces.
Indirectly from consumers. For example, through referral links from partner sites, searches or vehicle listing views collected from consumers in the course of connecting them with a seller.
Directly and indirectly from activity on our marketplaces as listed in our Open Road Privacy Policy. For example, from providing your contact information through the submission of an inquiry or interest contact form in our marketplaces or marketplace, we may include additional usage details about consumers collected automatically from our marketplace to a seller that is a commercial business (such as a recreational vehicle dealership). This may include information such as recent marketplace searches or previously viewed vehicle listing pages. However, we do not provide any indirect information to an individual private seller.
From third-parties that interact with us in connection with our marketplaces. For example, we engage a vendor that resolves your Internet Protocol address to a geographic location.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business or commercial purposes:

To fulfill or meet the reason for which the information is provided. For example, if you share your personal information to inquire about a listed vehicle, we will share that personal information with that seller to connect you with them;
To provide you with information, products, or services that you request from us, such as newsletters or to search our marketplaces for vehicles from listing sellers;
To provide you with email alerts, event registrations, and other notices concerning our products or services, or events or news, that may be of interest to you;
As a seller, or if you have posted a private listing to sell a vehicle or boat, we collect personal information from you to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including billing for advertising your listing;
To improve our website and present its contents to you;
For testing, research, analysis, and development of our marketplaces and existing and new products;
As necessary or appropriate to protect our rights and property, and the rights, property, or safety of us, our clients or others;
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
As described to you in a notice presented at the moment when we collect your personal information or as otherwise set forth in the CCPA; or
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category D: Commercial information.
Category F: Internet or other similar network activity.

We disclose your personal information for a business purpose to the following categories of third parties:

Service providers; and
Third parties to whom you have authorized us to disclose your personal information via requests to connect you with a seller or owner through a contact or inquiry form.

In the preceding twelve (12) months, we have not sold any personal information.

Your Rights and Choices

The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information during the twelve (12) month period preceding your request. Once we receive and confirm your request, we will disclose to you the information we are obligated to provide under the CCPA, which may include:

The categories of personal information we have collected about you;
The categories of sources from which we have collected your personal information;
Our business or commercial purpose for collecting your personal information;
The categories of third parties with whom we share your personal information;
The specific pieces of personal information we have collected about you (also called a data portability request); or
The categories of personal information we have disclosed for a business purpose, and the categories of third parties to whom we have disclosed such personal information.

Deletion Request Rights

You have the right to request that we delete some or all of your personal information that we have collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to whom we have furnished that information to also delete) your personal information from our (and their) records, unless an exception applies.

With respect to the exceptions, we may deny your deletion request if retaining the information is necessary for us or our service providers 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, 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 right of free speech, 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 your expectations based on your relationship with us;
Comply with a legal obligation; or
Make other internal and lawful uses of your information that are compatible with the context in which you provided it to us.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

Calling us at 800-677-4484
Email us at privacysupport@rvinsider.com
Fill out this Web Form directly.

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we 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.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity and authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time, we will inform you of the reason and extension period. If you have an account with us, we will deliver our response to your request to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding our receipt of your verifiable consumer request. The response we provide 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.

We do not charge a fee to process or respond to your verifiable consumer request unless your request is excessive, repetitive, or manifestly unfounded. If we determine that your request warrants a fee, we will explain to you how we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not, as a result of or due to you exercising any of your CCPA rights:

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.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. The date this Privacy Notice was last updated is identified at the bottom of this page. You are responsible for periodically visiting the Open Road marketplaces or website and this Privacy Notice to check for any changes.

Contact Information

If you have any questions or comments about this notice, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: 1-800-677-4484

Online: Fill out this Web Form directly.

Email: privacysupport@cycleinsider.com