Privacy Policy

This Privacy Policy describes how BuyHerePayHereNotes.com ("we," "us," or "our") collects, uses, and discloses information when you visit, use, or upload data through our website, buyherepayherenotes.com (the "Website").

IMPORTANT: BuyHerePayHereNotes.com is operated for CAR Financial Services, a direct buyer of BHPH accounts, notes, and portfolios. When you submit information through the Website, it is reviewed by CAR Financial for a potential direct purchase. We do not sell dealer submissions to outside buyer networks.

We understand the importance of privacy, especially in the sensitive financial industry, and we are committed to being transparent about how we collect, use, and share the information you provide to us.

1. Information We Collect

We collect information that you provide directly to us and information automatically collected when you use our Website.

• Contact and Dealership Information: When you use our form to request a portfolio valuation, we collect information such as your name, your dealership's name, phone number, and email address.
• Portfolio File Uploads: When you upload your BHPH loan portfolio file (in Excel, PDF, or other specified format) through our Website, you are providing us with the data contained within that file. This file is intended to contain information about the loans and potentially aggregated data, but please see Section 3 regarding the exclusion of customer personal information.

• Usage Information: We may collect information about your use of the Website, such as the pages you visit, the time spent on pages, clicks, and other actions you take.
• Device Information: We may collect information about the device you use to access the Website, including IP address, browser type, operating system, and unique device identifiers.
• Cookies and Similar Technologies: We may use cookies and similar tracking technologies to track activity on our Website and hold certain information. This may include technical data and information about your browsing behavior.

2. How We Use Your Information

We use the information you provide to review potential portfolio purchases and operate the Website. Specifically, we may use your information to:

• Review your contact information and portfolio data so we can evaluate a potential purchase.
• Provide, operate, and maintain the Website and related submission process.
• To communicate with you, respond to your inquiries, and provide customer support.
• To request follow-up information, discuss pricing, and move diligence or closing forward if both sides decide to proceed.
• To improve, personalize, and expand our Website and services.
• To understand and analyze how you use our Website.
• To develop new products, services, features, and functionality.
• For marketing and promotional purposes, such as sending you updates or information about our services that may be of interest to you (you may opt-out of these communications).
• To detect and prevent fraudulent submissions and other illegal activities.
• To comply with legal obligations and protect our legal rights.

Important: Any valuation, diligence request, or purchase proposal comes from CAR Financial Services based on the information you submit.

3. User Uploads: EXCLUSION OF CUSTOMER PERSONAL INFORMATION

Our service is designed to facilitate the valuation and potential acquisition of BHPH loan portfolios based on loan characteristics and performance data. We explicitly request and require that you DO NOT include any personally identifiable information ("PII") or sensitive data about your individual customers in the portfolio files you upload.

PII includes, but is not limited to, names, addresses, Social Security numbers, driver's license numbers, dates of birth, bank account numbers, or other information that could uniquely identify an individual customer.

Your Responsibility: You, as the dealership uploading the file, are solely responsible for ensuring that the data you provide does not contain customer PII and complies with all applicable privacy laws and regulations regarding your customers' data (such as GLBA, state privacy laws, etc.).

Our Handling: We design our processes and systems with the intent of not collecting or processing your customer's PII. While we implement security measures to protect the data you send, we cannot guarantee the security of customer PII that is mistakenly included in your uploads against our explicit instructions.

Our Right to Reject/Delete: We reserve the right to review uploaded files and may reject, delete, or request removal of any files found to contain customer PII, without prior notice or liability to you. Such files may not be used for valuation.

By uploading a file, you represent and warrant that the file does not contain any personally identifiable information of your customers and that you have the legal right to share the data contained in the file with us for the stated purpose.

4. How We Share Your Information

We do not sell your submission to outside buyer networks. We may share your information (specifically, your contact and dealership information plus uploaded portfolio data, excluding customer PII as described above) with:

We share your information (specifically, your contact/dealership information and the uploaded portfolio data, excluding customer PII as described above) with:

• CAR Financial Personnel and Advisors: Employees, representatives, attorneys, accountants, and other advisors who need the information to evaluate, document, or close a potential transaction.
• Service Providers: Trusted third parties who perform services on our behalf, such as hosting providers, data storage providers (for the uploaded files), analytics providers, and email service providers. These third parties are contractually obligated to protect your information and use it only for the purposes for which it was disclosed.
• Legal Requirements: If required to do so by law, court order, or in response to a valid legal process, such as a subpoena.
• Business Transfers: In connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• To Protect Our Rights: To enforce our terms and conditions, establish or exercise our legal rights, or defend against legal claims.

Dealer Fee Disclosure: We do not charge dealers a fee to submit portfolios or request a valuation. We also do not sell your information to third parties for unrelated marketing purposes.

5. Data Security

We implement reasonable technical and organizational measures designed to protect the information we collect from unauthorized access, disclosure, alteration, or destruction. These measures include SSL/TLS encryption for data transmission, secure storage facilities, and access controls to limit access to your data to only those who need it for business purposes.

Access Controls: Access to submitted data is limited to CAR Financial personnel and service providers who need it to review or process a submission.

However, please be aware that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security.

6. Data Retention

We retain your information, including uploaded portfolio files (after confirming they exclude customer PII), only for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of providing a valuation, potential transaction, legal, accounting, or reporting requirements.

If a transaction does not occur, we will retain the data only for a reasonable period necessary for our business records and potential future engagement, or as required by law. You may request deletion of your data as outlined in Section 7.

7. Your Choices and Rights

Depending on your location and applicable laws, you may have certain rights regarding your personal and dealership information, including:

• Access: The right to request access to the information we hold about you.
• Correction: The right to request correction of inaccurate or incomplete information.
• Deletion: The right to request the deletion of your information, subject to certain legal exceptions.
• Opt-Out: The right to opt-out of receiving marketing communications from us.

To exercise any of these rights, please contact us using the contact information provided in Section 11.

8. Third-Party Links

Our Website may contain links to third-party websites that are not operated by us. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services. We encourage you to review the privacy policies of every site you visit.

9. Children's Privacy

Our Website is not intended for individuals under the age of 18. We do not knowingly collect personally identifiable information from children under 18. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us. If we become aware that we have collected personal information from a child under age 18 without verification of parental consent, we take steps to remove that information from our servers.

10. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Effective Date" at the top. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

11. Contact Us

If you have any questions about this Privacy Policy, please contact us at robert.hicks@carfinancial.com.