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Privacy and Cookie Policy
WHO WE ARE.
Engine & Transmission Exchange, Inc. (“ETE Reman,” “ we” or “us”) is remanufacturer of automatic transmissions for import and domestic cars and trucks under the brands ETE REMAN, SHIFT SELECT, SHIFT PRO, NATIONAL POWERTRAIN, POWER TORQUE, THE TRANSMISSION AUTHORITY, POWERTRAIN WAREHOUSE, ATSG and AUTOMATIC TRANSMISSION SERVICE GROUP. We are based in Milwaukee, Wisconsin and pride ourselves for our work and customer service. We host several websites:
| etereman.com | buyete.com | shift-select.com |
| wewantyourcore.com | shiftproinc.com | national-trans.com |
| powertorquetrans.com | thetransmissionauthority.com | shiftpointusa.com |
| national-powertrain.com | powertrainwarehouse.com | ATSG.com |
(collectively, “Sites”). Our Sites provide information about our products and services (“Services”). If you use our Sites and Services, we collect various types of data from you. In some instances, the data will be considered “personally identifiable information,” “personal information” or “personal data” under applicable laws. Generally, this type of data is information that can be reasonably connected to an identified or identifiable individual.
The purpose of this Privacy Policy is to plainly and transparently disclose to you how we collect, use and share information, and how we attempt to safeguard the data you provide to us. We are committed to securing data that we collect concerning you (“you”) and complying with applicable data protection and privacy laws.
HOW TO CONTACT US.
If you have any questions regarding data protection or your rights, please contact us:
Engine & Transmission Exchange, Inc.
8155 N. 76th Street
Milwaukee, WI 53223-3203
800-934-9479
webprivacy@etereman.com
WHY AND HOW WE COLLECT DATA.
ETE Reman collects, processes and uses personal data to operate effectively, to communicate with our customers, and provide users of our Sites with useful and positive experiences. The legal basis for our collection of personal data is with your consent, for our legitimate business purposes and/or to comply with our legal and contractual obligations. We obtain person information directly from you, through cookies and other technologies, and from third parties as described in this Policy and any other privacy notices we may provide to you when you interact with us.
a. Information from you. You provide data directly to us when you interact with us, set up an account or submit a form to us with personal information (for example, when you send us information through our contact forms). You are not obligated to provide ETE Reman with any information, but in some cases, it may be necessary to process your requests and/or to provide services or information to you.
b. Cookies & Technology. We collect data by automatically recording how you interact with our Sites and emails using technologies like cookies. More information on cookies is provided below.
PROTECTING YOUR PRIVACY GENERALLY.
a. Industry-Standard Protection . We utilize industry-standard security measures to safeguard the information we collect, maintain and use. These measures include technical and procedural steps to protect your data from misuse, unauthorised access or disclosure, loss, alteration or destruction. However, we do not guarantee the performance or adequacy of such security measures.
b. Limitation on Access . Access to any personal information we collect and store is generally restricted to our employees and/or contractors who require it to perform a job or other contracted function. We require vendors and contractors we work with to use reasonable, industry standard protocols to maintain the confidentiality, security, and integrity of information.
c. Payment Information. When you make a payment on our Sites, you may provide payment card information and/or other payment details. We use a Payment Card Industry compliant third-party vendor for payment services. We do not process or store payment card information.
CHILDREN’S PRIVACY.
We do not intentionally collect any personal information from children under the age of sixteen (16). We do not sell the personal information of children under the age of sixteen (16). If you are under 16, please do not use the Sites or provide personal information to us.
TYPES OF INFORMATION WE COLLECT.
Through your use of the Sites and Services, we may collect the following categories of personal data from you.
· Contact information (name, company name, job title, mailing address, telephone number, electronic mail address)
- Profile information
- Inquiry Information
· Payment information, including payment card information
· Communications to and from you through the Sites and/or Services
- Your login information
- Customer account number
- Vehicle Identification Number (VIN)
- Order number
- Order information
- Shipping information
· Photos and other multimedia content you provide to us
- Any other information you provide to us.
b. Information We Collect As You Navigate Our Sites . We use cookies and other tracking technologies (such as pixels and web beacons) (collectively, “Cookies”) to collect information as you navigate our Sites. Cookies are small files of information that are stored by your web browser software on your computer hard drive, mobile or other devices (e.g., smartphones or tablets).
We use Cookies to: (a) estimate audience size and usage patterns; (b) understand and save your preferences for future visits, allowing us to customize the Sites and Services to your individual needs; (c) advertise new content, events and services that relate to your interests; (d) keep track of advertisements and search engine results; (e) compile aggregate data about Site traffic and Site interactions to resolve issues and offer better Site experiences and tools in the future; and (f) recognize when you return to the Site(s).
The Cookies we use collect the following types of personal data through your use of the Sites and Services:
- Usage Information . We collect information such as which of the pages on the Sites you access, the frequency of access, and what you click on while on the Sites.
- Technical Information. We collect technical information about your connection to our Sites, including the Internet protocol (IP) address, browser type and version, browser plug-in types and versions.
- Device Information . We collect information about the device you are using, such as hardware model, operating system, application version number.
- Mobile Device Information . In addition to the device information listed above, when you access our Sites via a browser on your mobile device, we collect and aggregate information about whether you are accessing the Sites via a mobile device or tablet, device type, and carrier.
- Location Information. We collect location information from Sites visitors on a city-regional basis.
We set some Cookies ourselves and others are set by service providers. We use Cookies set by service providers to provide us with useful information to help us improve our Sites and Services, to conduct advertising, and to analyze the effectiveness of advertising. See Section 8 for more information.
c. How To Opt-Out of Cookies & Learn More. Cookies can be blocked by changing your Internet browser settings to refuse all or some Cookies. If you choose to block all Cookies (including essential Cookies) you may not be able to access all or parts of the Sites. You can find out more about Cookies and how to manage them by visiting www.AboutCookies.org . You can also learn about which third parties have currently enabled Cookies for your browser or mobile device and how to opt-out of some of those Cookies by accessing the Network Advertising Initiative’s website or the Digital Advertising Alliance’s website . For more information on mobile specific opt-out choices, visit the Network Advertising Initiative’s Mobile Choices website .
HOW WE USE YOUR PERSONAL DATA
We use the personal data we collect to provide the Services to you, to provide you with information and Services, to improve our Sites and Services, and to protect our legal rights. In addition, we may use the personal data we collect to:
· Allow you to participate in features we offer on the Sites
- Process your account registration
- Process your orders
- Process your product returns
· Email you information about our products or services
· Contact you regarding our products, services or promotions that we feel may be of interest to you
· Communicate with you about our Sites or Services or to inform you of any changes to our Sites or Services
- Provide support
· Provide educational videos, webinars and other materials
- Tailor our content, advertisements and offers
- Maintain and improve our Sites and Services
- Defend our legal rights and the rights of others
· Determine your location and manage digital content rights
- Efficiently maintain our business
- Comply with applicable law.
INFORMATION WE SHARE WITH THIRD PARTIES
We do not sell personal data. We may share the information that we collect about you in the following limited ways:
a. With Service Providers . We may share information with service providers who:
· perform data services on our behalf (e.g., email, hosting, maintenance, backup, analysis, etc.)
- process payments on our behalf
· prepare, deploy and analyze advertising content on our behalf
- provide other services on our behalf
b. Amongst our Business Units. We share information with affiliates with whom we offer co-branded services or engage in joint marketing activities with.
c. Other. We also may share information with other persons or entities if you expressly consent to or request disclosure.
c. To Meet Our Legal Requirements or Exercise Our Rights . We may share information with third parties in the following instances:
- When we are required to do so by law
· In connection with any legal proceedings or prospective legal proceedings
· To establish, exercise, or defend our legal rights, including providing information to others for the purposes of fraud prevention
· To any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal data where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal data
· We may share information with other persons or entities as part of our own corporate transactions, such as during financing of our business, or any business or asset sale or merger.
THIRD PARTY CONTENT AND ADVERTISING SERVICES
Third-Party Links
Our Sites may contain links to websites, platforms, applications or services operated by third parties. These third parties may use their own cookies, web beacons and other tracking technology to collect information about you. They may also ask you to provide information. This Privacy Policy does not cover those practices and we encourage you to review the privacy policies and procedures of any third-party websites and services you use. We may engage or work with other third parties to serve advertisements or other analytics on our Sites or Services.
We may use Google Analytics, a web analytics service provided by Google, Inc. Google Analytics uses Cookies or other tracking technologies to help us analyze how users interact with the Sites and Services, compile reports on their activity, and provide other services related to their activity and usage. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a returning visitor, and any referring website. The technologies used by Google Analytics do not gather information that personally identifies you. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies . To learn more about Google’s partner services and to learn how to opt-out of tracking of analytics by Google, click here .
We may use Google AdWords for targeting and remarketing. If we do, we will collect data about your activities that does not personally or directly identify you when you visit our Site, the website for which we serve advertisements, or the website and online services where we display advertisements. We use the information we collect to serve you more relevant advertisements (referred to as “Remarketing”). We collect information about where you saw the ads we serve you and what ads you clicked on. Users may opt out of Google’s use of cookies by visiting the Google Advertising Opt-out Page.
Google reCAPTCHA
We may use Google reCAPTCHA, a free service provided by Google, Inc., to protect our Site from spam and abuse. Google reCAPTCHA uses advanced risk analysis techniques to decipher humans and bots. Google reCAPTCHA works differently depending on what version is deployed. For example, you may be asked to check a box indicating that you are not a robot or Google reCAPTCHA may detect abusive traffic without user interaction. Google reCAPTCHA works by transmitting certain types of information to Google, such as the referrer URL, IP address, visitor behavior, operating system information, browser and length of the visit, cookies, and mouse movements. Your use of Google reCAPTCHA is subject to Google’sPrivacy Policy and Terms of Use. More information as to Google reCAPTCHA and how it works is available here.
We may use cookies and other technologies on our Sites to collect information about your online activities over time and across different websites you visit in order to provide you with interest-based advertising. You can generally opt-out of receiving interest-based advertisements from members of the Network Advertising Initiative or the Digital Advertising Alliance by visiting their opt-out pages: ( http://www.networkadvertising.org/choices/ ) and ( http://www.aboutads.info/choices/ ). When you opt-out using these links, please note that you may still receive advertisements. They just will not be personalized based on your interests.
Some internet browsers incorporate a “Do Not Track” feature that signals to website you visit that you do not want to have your online activity tracked. Given that there is not a uniform way that browsers communicate the “Do Not Track” signal, the Sites do not currently interpret, respond to or alter its practices when it receives “Do Not Track” signals.
HOW TO ACCESS & CONTROL YOUR PERSONAL DATA
We respect your privacy and try to provide ways for you to choose whether to share your information with us or any third parties.
You may decline to provide information. You have the right to decide not to share information with us through our Sites.
Review and request changes to your personal data. You may use your account to access, correct, or view certain personal data we have collected which is associated with your account. You may also contact us at webprivacy@etereman.com to request information or changes.
Request deletion. You may submit a request to update or delete your personal data by contacting us at us at webprivacy@etereman.com.
Please note, however, that if you choose not to provide us with certain information OR ASK US TO DELETE YOUR INFORMATION, we may not be able to provide you with the full functionality of our Sites or SERVICES. IN ADDITION, IN SOME CIRCUMSTANCES, WE MAY NOT BE ABLE TO MODIFY OR DELETE DATA DUE TO OUR OWN OBLIGATIONS.
Marketing communications.
You can always choose whether you wish to receive communications we send
via email, SMS messages, telephone calls and postal mail. To do so, contact
us at webprivacy@etereman.com. You can also opt out from receiving
interest-based advertising from us on Facebook and Google by adjusting your
settings on those platforms.
Control Cookies. You can learn more about which entities have currently enabled cookies for your browser or mobile device and how to opt-out of some of those cookies by accessing the Network Advertising Initiative’s website or the Digital Advertising Alliance’s website . For more information on mobile specific opt-out choices, visit the Network Advertising Initiative’s Mobile Choices website .
SECURITY
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Sites or Services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Sites; any transmission is at your own risk.
DATA RETENTION
We will store your information for as long as you are a customer, our performance of the Services require, and as long as our ethical or legal obligations require. We may keep records of transactions with you for a period of up to seven (7) years to comply with the IRS requirements.
ACCESSIBILITY
We are committed to ensuring this Privacy Policy is accessible to individuals with disabilities. If you wish to access this Privacy Policy in an alternate format, or would like to report an issue you are experiencing, please email us at webprivacy@etereman.com. You expressly agree to attempt to resolve any and all issues with accessibility directly with us and in good faith prior to instituting any legal action against us.
Notice to Nevada residents
Nevada law allows Nevada residents to opt-out of the sale of certain types of personal information. Subject to a number of exceptions, Nevada law defines “sale” to mean the exchange of certain types of personal information for monetary consideration to a person for the person to license or sell the information to additional persons. We do not currently sell personal information as defined in the Nevada law. However, if you are a Nevada resident, you still may submit a verified request to opt-out of sales and we will record your instructions and incorporate them in the future if our policy changes. Opt-out requests may be sent to webprivacy@etereman.com.
NOTICE TO CALIFORNIA RESIDENTS
This notice reflects our good faith understanding of the CCPA, the California Privacy Rights Act (“CPRA”), other California privacy laws and our current data practices. However, there are varying interpretations of the California laws’ requirements. We may update our practices and this notice as the CCPA and the CPRA continue to develop, and as we continue to develop our compliance program.
This Notice to California Residents (“Notice”) applies to “Consumers” as defined by the CCPA and is a supplement to the other sections of our Privacy Policy. This Notice covers our collection, use, disclosure, and sale of California Consumers’ “Personal Information” (“ PI”) as defined by the CCPA. Some of the data we collect and process is not subject to CCPA consumer rights. For example, we collect and process the following types of information that is currently exempted to some degree from the CCPA: (a) business-to-business information; (b) employee or personnel information; and (c) publicly available information (as defined by the CCPA).
The CCPA defines “personal information” or PI to mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. PI does not include publicly available, deidentified or aggregated information.
A. YOUR RIGHTS. Under the CCPA, you have the following rights:
|
Number
|
Description of your right |
|
Right 1
|
The right to know what personal information we collect about you. |
|
Right 2
|
The right to know whether we sell or disclose your personal information, and if so, to whom. |
|
Right 3
|
The right to say no to the sale of personal information. |
|
Right 4
|
The right to access your personal information. |
|
Right 5
|
The right to receive equal service and pricing from us, even if you exercise your privacy rights. |
Right to Know: You have the right to request that we disclose to you the PI we collected about you in the 12-month period preceding your request. This right includes the right to request: (1) specific pieces of PI we have collected about you; (2) categories of PI we have collected about you; (3) categories of sources from which the PI was collected; (4) categories of PI that we sold or disclosed for a business purpose about you; (5) categories of third parties to whom your PI was sold or disclosed for a business purpose; and (6) the business or commercial purpose for collecting or, if applicable, selling your PI.
Right to Request Deletion: You have the right to request that we delete your PI that we have collected from you. Note that if you request that we delete your information, we may be unable to provide you with certain Services or access to the Sites, and you may become ineligible for some of our programs.
Right to Opt-Out of the Sale of Personal Information : The CCPA defines “sell” to mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a California resident’s PI to another business or a third party for monetary or other valuable consideration. We do not sell personal information relating to anyone, including children under the age of 16.
Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights.
How to Exercise Your Rights: To exercise your “right to know”, “right to opt-out of sale” or your “right to request deletion,” email us at webprivacy@etereman.com or leave a message with your name, request, and contact information for a follow up call on our toll-free privacy line: 1-800-934-9479
Under the CCPA, you may exercise these rights yourself or you may designate an authorized agent to make these requests on your behalf. We reserve the right to request that your authorized agent have written permission from you to make requests on your behalf and may need to verify your authorized agent’s identity.
Verification Required: Please note that to protect your information, we may need additional information from you to verify your identity before processing your request. We will verify your information through your account, email or via telephone.
We will comply with any CCPA requests you submit upon verification of your identity and, to the extent applicable, the identity of the California on whose behalf you are making such request. We will authenticate your identity through email or by telephone. If you are not an ETE Reman customer or job seeker, we will verify your identity by associating the information you provide us to any PI that we have collected or otherwise using our partners for such purposes.
If you are an authorized agent, send us proof that the consumer gave you written permission to submit the request and we will verify your identity as provided above. We may also require the consumer to verify their own identity with us and/or directly confirm with us that they have given you permission to submit the request.
We will verify your identity either to a “reasonable degree of certainty” or a “reasonably high degree of certainty” depending on the sensitivity of the PI and the risk of harm to you by unauthorized disclosure or deletion as applicable.
For requests to access categories of PI and for requests to delete PI that is not sensitive and does not pose a risk of harm by unauthorized deletion, we will verify your identity to a “reasonable degree of certainty” by verifying at least two data points that you previously provided to us and which we have determined to be reliable for the purpose of verifying identities.
For requests to access specific pieces of PI or for requests to delete PI that is sensitive and poses a risk of harm by unauthorized deletion, we will verify your identity to a “reasonably high degree of certainty” by verifying at least three pieces of PI previously provided to us and which we have determined to be reliable for the purpose of verifying identities. In addition, you will be required to submit a signed declaration under penalty of perjury stating that you are the individual whose PI is being requested.
B. COLLECTION AND USE OF PERSONAL INFORMATION
During the past twelve months, we have collected the categories of PI described in Section 6 from California residents for the purposes set forth in Sections 3 and 7, and may have disclosed such data to the categories of recipients set forth in Sections 8 and 9.
Specific categories of PI we have collected in the last 12 months include:
· Identifiers (name, alias, postal address, online identifier, internet protocol address, email address, account name, Social Security number, driver’s license number, passport number)
· Unique personal identifiers (device identifier; cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology; customer number, unique pseudonym or user alias; telephone numbers, or other forms of persistent or probabilistic identifiers that can be used to identify a particular consumer or device)
· Telephone number
· Credit and debit card number
· Geolocation data
· Commercial information (records of personal property, products or services purchased, obtained or considered; other purchasing or consuming histories or tendencies; or other commercial information)
o Repair Orders for warranty service verification
The PI is collected from California residents. Not all categories of Personal Information are collected from each source.
In addition to the purposes set forth above in Sections 3 and 7, we currently collect and have collected the above categories of PI for the following business or commercial purposes:
· Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
· Debugging to identify and repair errors that impair existing intended functionality
· Short-term, transient use, provided that the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction
· Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider
· Undertaking internal research for technological development and demonstration.
C. DISCLOSURE AND SALE OF PERSONAL INFORMATION
We do not sell PI of any individual, including individuals under 16 years old. The following table identifies the categories of PI that we have disclosed for a business purpose to service providers in the 12 months preceding the Effective Date of this Privacy Policy and, for each category, the category of service providers or third parties to whom the Personal Information was sold or disclosed:
|
Category of Personal Information |
Category of Third Parties to Whom Information Was Disclosed |
|
Name, postal address, email address, phone number, professional and employment related information, VIN |
Shipment Processors/Carriers |
|
Name, email address |
Customer Satisfaction Survey Providers |
|
Internet protocol address, Unique personal identifiers (device identifier; cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology; customer number), Internet or other electronic network activity information (information regarding consumer’s interaction with Site), geolocation data |
Advertising networks Data analytics providers Internet Service Providers |
|
Name, postal address, credit and debit card numbers |
Payment card processing provider |
SHINE THE LIGHT LAW: If you are a California resident, California Civil Code § 1798.83 permits you to request information regarding the disclosure of your personal information by us to third parties for the third-parties’ direct marketing purposes (as those terms are defined in that statute). ETE Reman does not sell or disclose information to third parties for their direct marketing purposes.
NOTICE TO RESIDENTS OF THE EUROPEAN ECONOMIC AREA.
We do not operate in the European Economic Area and do not target or market our Sites or Services to individuals in the European Economic Area. However, to the extent the General Data Protection Regulation (“ GDPR”) may apply to you, you have certain rights. The GDPR allows us to collect and use personal information from individuals within the European Economic Area only for one or more of the following reasons:
1. To fulfill a contract we have with you;
2. When we have a legal duty;
3. When it is in our legitimate interest; or
4. When you provide consent.
If you reside in the European Economic Area, you have a number of rights under data protection laws in relation to the way we process your personal data. These are set out below. You may contact us directly to exercise any of these rights, and we will respond to any request received from you within one month from the date of the request. In exceptional circumstances we may need to extend this timescale, but we will always tell you in advance if we do, and our reasons why.
|
Number
|
Description of your right |
|
Right 1
|
A right to access personal data held by us about you, as well as information about how we are using your data. |
|
Right 2
|
A right to require us to rectify any inaccurate personal data held by us about you. |
|
Right 3
|
A right to require us to erase personal data held by us about you, and where the personal data has been made public, for other controllers processing the personal data to also erase links to, or copy or replication of, such personal data. This right will only apply where (for example): we no longer need to use the personal data to achieve the purpose we collected it for; or where you withdraw your consent if we are using your personal data based on your consent; or where you object to the way we process your data (in line with Right 6 below). |
|
Right 4
|
A right to restrict our processing of personal data held by us about you. This right will only apply where (for example): you dispute the accuracy of the personal data held by us; or where you would have the right to require us to erase the personal data but would prefer that our processing is restricted instead; or where we no longer need to use the personal data to achieve the purpose we collected it for, but you require the data for the purposes of dealing with legal claims. |
|
Right 5
|
A right to receive personal data, which you have provided to us, in a structured, commonly used and machine-readable format. You also have the right to require us to transfer this personal data to another organization, at your request. |
|
Right 6
|
A right to object to our processing of personal data held by us about you (including for the purposes of sending marketing materials to you). |
|
Right 7 |
A right to withdraw your consent, where we are relying on it to use your personal data (for example, to provide you with marketing information about our services or products). |
If you have any concerns regarding our processing of your personal data, or are not satisfied with our handling of any request by you in relation to your rights, please get in touch with our team through the contact information provided in Section 2 of this Privacy Policy. You may also reach out to your applicable Data Protection Authority (“DPA”) for more information. There is a DPA located in each EU Member State.