Privacy Policy
Effective Date: May 15, 2024
Your privacy is a top priority for us. THECRM is a service-first CRM company that builds software designed to improve customer relationships. PLEASE READ THIS PRIVACY POLICY CAREFULLY as this describes the information that we gather on or through the Service, how we use and disclose such information, and the steps we take to protect such information. This Policy explains your rights in relation to your personal information and how to contact TheCRM Corporation or the supervisory authorities in the event you have a complaint.
a. Definitions
i. “We, Us, Our” means TheCRM Corporation ii. “Our Privacy Representative” means Erick Olson, email: privacy@thecrm.com, mailing address: 325 N Maple Dr Suite #15157 Beverly Hills CA 90210.
iii. “Our Data Protection Officer” means Richard Keith Latman, email: privacy@thecrm.com, mailing address: 325 N Maple Dr Suite #15157 Beverly Hills CA 90210.
iv. “Personal Information” means any information relating to an identified or identifiable individual.
b. Personal Information We Collect:
i. Categories of Information:
  1. Required Identifiers: First Name, Last Name, Email, Username or Username, and Birthdate.
  1. Optional Identifiers: Driver License Number, Phone Number, Work Phone Number, Mobile Phone Number, Licensee’s Occupation, Licensee’s Primary Shipping Address, whether Licensee is a Celebrity, Marital Status of Licensee, Frist and Last Name of Licensee’s Assistant, Title of Licensee’s Assistant, Phone Number of Licensee’s Assistant, Email Address of Licensee’s Assistant, Preferred Method of Payment, Licensee’s Credit Card Numbers, Licensee’s Optional Profile Photo, Name of Licensee’s Significant Other, Licensee’s Suffix, Licensee’s vehicle information including: VIN Number, License Plate Number, Year of Vehicle Production, Vehicle Make, Vehicle Model Number, and Vehicle Color, Licensee’s credit information, and financial data that is customarily collected relevant to the purchase or sale of a motor vehicle.
  1. Characteristics of Protected Class State/Federal: Licensee’s Gender
ii. Professional/Employment Information: Licensee’s Occupation
iii. Commercial Information: Licensee’s purchasing history through the TheCRM App. and Website.
  1. TheCRM Corporation uses Licensee’s Data from the information listed above to create a profile about Licensee
reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
iv. THE INFORMATION COLLECTED ASSISTS THECRM CORPORATION, IF YOU DO NOT PROVIDE PERSONAL INFORMATION WE ASK FOR, IT MAY DELAY OR PREVENT US AND OUR LICENSED AFFILIATES FROM PROVIDING AUTOMOTIVE DATA SERVICES TO YOU.
c. How We Collect Your Personal Information
i. We collect different types of Personal Information directly from the Licensee via telephone, text, website, email, and/or the THECRM App or CRM SUITE.
ii. We may also collect personal information by:
  1. Publically accessible sources;
  1. Directly from a third party e.g. a credit reporting agency, sanctions reporting agency, or customer due diligence providers;
  1. A third party with Licensee’s consent e.g. Licensee’s bank.
  1. From Cookies on our website;
  1. Via THECRM Corporation’s internal and external IT Systems
a. Door entry systems and visitor logs at physical automotive dealerships;
b. Automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV access control systems, communication systems, email and instant messaging systems; and
c. Any other relevant systems.
d. What We Use Your Personal Information for
i. To Provide Products and Services to You the Consumer and Automotive Dealerships Across the United States – The data is collected and stored to ensure quality of performance of our contract with you and our licensed affiliates. We use your data to make sure that the vehicle buying process meets your specific needs and desires.
ii. To Prevent and Detect Fraud Against You or THECRM Corporation – The data is collected and stored to carry out our legitimate business interest as a data collection and services Company and those interests of third parties we work with to minimize fraud that could be damaging to you and us.
iii. To Conduct Identity Checks on Our Customers – This is done to maintain compliance with our legal and regulatory obligations.
iv. To Conduct Screening for Financial Sanctions and/or Embargoes – This is done to maintain compliance with our legal and regulatory obligations.
v. To Ensure that Business Policies are Adhered to e.g. Policies Covering Security and Internet Use - For our legitimate interests or those of a third parties, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you and our licensed affiliates.
vi. Operational Reasons, Such As Improving Efficiency, Training and Quality Control - For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you and our licensed affiliates at the best price.
vii. Ensuring the Confidentiality of Commercially Sensitive Information - For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information To comply with our legal and regulatory obligation.
viii. Updating and Enhancing Customer Records - For the performance of our contract with you or to take steps at your request before entering into a contract to comply with our legal and regulatory obligations for our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products.
ix. Statutory Returns - The data is collected and stored to comply with our legal and regulatory obligations.
x. Ensuring Safe Working Practices, Staff Administration, and Assessments – We collect and store customer data in order to comply with our legal and regulatory obligations. Also, for our legitimate interests or those of a third party e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you.
xi. Marketing Our Services and Those of Selected Third Parties To:
  1. Existing and Former Customers of TheCRM Corporation;
  1. Third Parties Who Have Previously Expressed An Interest Our Services;
  1. Third Parties With Whom We Had No Previous Dealings.
a. Your data is collect for our legitimate interests of those of third parties i.e. to promote our business to existing and former customers.
xii. External Audits and Quality Checks e.g. for ISO or Investors in People Accreditation and the Audit of Our Accounts – The purpose of collecting your data is to comply with our legal and regulatory obligations and for our legitimate interest of a third party i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards.
xiii. THE ABOVE DOES NOT APPLY TO SPECIAL CATEGORY INFORMATION, WHICH WE WILL ONLY PROCESS WITH YOUR EXPLICIT CONSENT.
e. Promotional Communications
i. We may use your Personal Information to send you updates by email, text message, push notification, telephone, post about our products and services, including exclusive offers, promotions, or new products and services.
ii. We have a legitimate interest in processing your personal information for promotional purposes. This means we do not usually need your
consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
iii. We will always treat your personal information with the utmost respect and NEVER SELL OR SHARE IT with other organizations outside the THECRM Corporation group for marketing purposes.
iv. You have the right to opt out of receiving promotional material by:
  1. Contracting THECRM Corporation directly via written letter to: Erick Olson at 325 N Maple Dr Suite #15157 Beverly Hills CA 90210.
  1. Using the Unsubscribe link in the Emails or respond to the text messages by texting “STOP”
  1. By updating your marketing preferences on our website www.thecrm.com.
  1. We may ask you to update your marketing preferences if you instruct us to provide further products and/or services in the future or if there are changes in the law, regulation, or the structure of our business.
f. Who We Share Your Personal Information With
i. Our affiliates, including companies within the TheCRM Corporation group and/or umbrella;
ii. Service providers we use to help deliver our products and/or service to you, such as payment service providers and delivery companies;
iii. Other third parties we use to help us run our business, such as marketing agencies or website hosts;
iv. Third parties approved by you, including social media sites you choose to link your account to or third party payment providers.
v. Our insurers and brokers
vi. Our banks
vii. We only allow our service providers to handle your Personal Information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, e.g. in relation to ISO [or Investors in People] accreditation and the audit of our accounts.
viii. We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
ix. We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
x. We will not share your personal information with any other third party.
g. Personal Information We Sold or Disclosed for Business Purposes
i. WE HAVE NOT SOLD OR DISCLOSED TO A THIRD PARTY ANY PERSONAL INFOMRATION THAT IDENTIFIES, RELATES TO,
DESCRIBES, IS CAPABLE OF BEING ASSOCIATED WITH YOU, OR COULD BE REASONABLY LINKED, DIRECTLY OR INDIRECTLY, WITH A PARTICULAR CONSUMER OR HOUSEHOLD.
h. Where Your Information is Held. Information may be held at our offices and those of the TheCRM Corporation group, third party service providers, representatives and agents as described above. See Who We Share Your Information With.
i. How Long Your Personal Data Will Be Kept. We will keep your personal information while you have an account with us or while we are providing products and services to you. Thereafter we will keep your information for as long as is necessary:
i. To respond to any questions, complaints or claims made by you or on your behalf;
ii. To show that we have treated you fairly; or
iii. To keep records as required by law.
  1. We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information. When it is no longer necessary to retain your information, we will delete or anonymize it.
j. THIS SECTION APPLIES ONLY TO CALIFORNIA CONSUMERS. Your Rights Under the California Consumer Privacy Act of 2018 (CCPA) if you are resident of California.
i. Disclosure of the Personal Information We Collect:
  1. You have the right to know:
a. The categories of personal information we have collected about you;
b. The categories of sources from which the personal information is collected;
c. Our business or commercial purpose for collecting or selling personal information;
d. The categories of third parties with whom we share personal information, if any; and
e. The specific pieces of personal information we have collected about you.
f. Please note that we are not required to:
i. Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained; • Re-identify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or • Provide the personal information to you more than twice in a 12-month period.
  1. Personal Information Sold or Used for Business Purposes:
a. In connection with any personal information we may sell or disclose to a third party for a business purpose, you have the right to know:
i. The categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold; and
ii. The categories of Personal Information that we disclosed about you for a business purpose.
iii. You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to opt-out of the sale or disclosure of your personal information. If you exercise your right to opt-out of the sale or disclosure of your personal information, we will refrain from selling your personal information, unless you subsequently provide express authorization for the sale of your personal information. To opt-out of the sale or disclosure of your personal information, visit our homepage and click on the Do Not Sell My Personal Information link here: www.thecrm.com/PrivacyPolicy.
  1. Right to Deletion:
a. Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:
i. Delete your personal information from our records; and
ii. Direct any service providers to delete your personal information from their records.
iii. Please note that we may not delete your personal information if it is necessary to:
iv. Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
v. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
vi. Debug to identify and repair errors that impair existing intended functionality;
vii. Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
viii. Comply with the California Electronic Communications Privacy Act;
ix. 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 our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
x. Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
xi. Comply with an existing legal obligation; or
xii. Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
  1. Protection Against Discrimination:
a. You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things:
i. Deny goods or services to you;
ii. Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
iii. Provide a different level or quality of goods or services to you; or
iv. Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
v. Please note that we may charge a different price or rate or provide a different level or quality of goods and/or services to you, if that difference is reasonably related to the value provided to our business by your personal information.
k. Keeping Your Personal Data Secure. We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We continually test our systems and are AWS Dynamo DB certified which means we follow top industry standards for information security We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
l. How to Exercise Your Rights. If you would like to exercise any of your rights as described in this Privacy Policy Please:
i. Complete a data subject request form available on our website at www.thecrm.com/PrivacyPolicy; or
ii. Call us toll free at: 1-866-460-2999
iii. Email us at privacy@thecrm.com.
  1. Please note that you may only make a CCPA-related data access portability request twice within a 12-month period.
  1. If you choose to reach us directly via email, phone, or in writing, you will need to provide us with:
a. Enough information to identify you e.g. your full name, address and customer or matter reference number.
b. Proof of address e.g. your driver license or passport and a recent utility or credit card bill; and
c. A description of the right you wish to exercise and then information to which your request relates.
We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.
Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.
m. Changes to this Privacy Notice. We may change this Privacy Notice from time to time – when we do, we will inform you and give proper notice via email, text, push notification, or by updating our website or other means of contact.
n. How to Contact Us. Please contact us or our data protection officer Richard Keith Latman by post, email, or telephone if you have any questions about this Privacy Policy or the information we hold about you.
i. Our Contact Details:
Erick Olson
TheCRM Corporation
325 N Maple Dr
Suite #15157
Beverly Hills CA 90210.
When contacting us, please clearly state your request, including your name, mailing address, email address, and phone number.
DO YOU NEED EXTRA HELP? IF YOU WOULD LIKE THIS NOTICE IN ANOTHER FORMAT (FOR EXAMPLE: audio, large print, or braille) Please contact us at the above listed address.
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