Collection of Private Information

We may collect the following kinds of Private Information about you from the following sources:

• Information you provide on applications, forms, or other correspondence, such as your name, address, social security number and income.
• Information about your transactions with us or others, such as your account balance and payment history.
• Information we receive from consumer reporting agencies, credit references, employers, insurance companies and insurance agencies, such as your credit history and creditworthiness, and information that we obtain to verify employment history or that insurance coverage is in force.

Disclosure of Private Information

We may disclose some or all of the Private Information (described above) under the following circumstances:

• To Marketing Service Providers and Joint Marketing Partners. We may disclose Private Information to companies that perform marketing services for us or to other financial institutions with which we have joint marketing agreements.
• With Non-Affiliated Third Parties. We may disclose Private Information about you with non-affiliated third parties as permitted by law.

Protection of Information

We restrict access to your Private Information to our employees who need to know that information to provide products or services to you and to perform their job duties, and to other persons necessary to assist us in providing you with products or services. Additionally, we maintain physical, electronic, and procedural safeguards to protect your Private Information in a manner consistent with industry standards for similar companies, and in compliance with applicable laws.

Social Security Number Privacy Policy:

Commonwealth Audi has established a Safeguards Policy designed to protect the confidentiality of all Social Security Numbers (SSN). Reasonable care is exercised to ensure confidentiality and prohibit unlawful disclosure of SSNs. Access to SSNs are limited and restricted to only those who have business reasons for accessing it. Documents that need to be disposed are immediately shredded. Penalties for violation of this policy are strictly enforced.

CA Privacy

If you are a California resident and customer of our dealership, California Senate Bill 27 provides that we will, upon your request, provide you with the following information:

• Any of your personal information that we disclosed to third parties for the third parties direct marketing purpose during the immediately preceding calendar year; and
• The names and addresses of all third parties that received your personal information from us for the third parties direct marketing purpose during the preceding calendar year. If you wish to request the foregoing information from us, please e-mail us at privacyrights@penskeautomotive.com.