Customer Privacy Notice

Website Privacy Policy

Last Updated:   September 18, 2024 

American Credit Acceptance LLC (also d/b/a Spartan Financial Partners), including agents acting on our behalf (“ACA”, “we,” “us,” “our”), values the trust you place in us when you use the ACA website and our affiliated websites and online services, including ACA’s Customer Portal (collectively, our “Websites”). This Privacy Policy describes our collection, use, disclosure, and protection of your information in connection with our Websites, regardless of how you access or use them, including through mobile devices.

BY USING THE WEBSITES, YOU ARE ACCEPTING THE TERMS OF THIS PRIVACY POLICY AND OUR TERMS OF SERVICE, AND YOU ARE CONSENTING TO OUR COLLECTION, USE, DISCLOSURE, AND PROTECTION OF YOUR INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY.

If you do not agree to the terms of this Privacy Policy, please do not use the Websites. We may make changes to this Privacy Policy from time to time and will post these changes to the Websites. Your continued use of the Websites following the posting of any changes will mean you accept those changes.

This Privacy Policy does not apply to information that you may submit to third-party websites and mobile applications that may link to the Websites or be linked to on the Websites.  We are not responsible for the actions or privacy practices of third-party websites and applications; please consult those websites and applications directly to understand their privacy practices. 

ACA also maintains a separate financial privacy notice as required by the federal Gramm-Leach-Bliley Act. You can request a copy of this notice by emailing [email protected] and specifying that you would like a copy of this notice.

Information We Collect About You

We collect, process, and retain information from you and any devices you may use when you interact with the Websites, and in other ways described below.

Information You Give Us:  We receive and store information you provide to us through the Websites when you register for an account or give it to us in any other way, including your name, mailing address, phone number, email address, your vehicle’s identification number, and business or employment information.

Information We Automatically Collect:  We collect information about your use of the Websites, such as the pages you view and other interactions you have.  We receive and store certain types of information whenever you interact with the Websites.  The Websites use “cookies,” tagging, and other tracking technologies to help enable us to enhance or personalize your experience.  This information includes computer and connection information such as statistics on your page views, traffic to and from the Websites, referral URL, your IP address, and device identifiers.  This information also may include your browsing history, transaction history, and your web log information. 

Information From Other Sources:  We may supplement the personal information we collect with information from third parties or collected offline, such as information collected by ACA over the phone, and add it to your account information.  This information may include, but is not limited to, demographic information, additional contact information, group affiliations, and occupational information. We also may collect information about you from credit reporting agencies, for example, to determine your creditworthiness, credit score, and credit usage. 

How We Use Your Information

We use your information to help us personalize and continually improve your experience on the Websites, including fulfilling requests for information, analyzing and compiling trends and statistics, and communicating with you.

We also may use your information to:

  • Provide, maintain, and improve the Websites and for internal or other business purposes;
  • Fulfill your requests for information and provide the services you request;
  • Communicate with you about your account or transactions with us;
  • Provide customer support and communicate with you about features and enhancements on our Websites;
  • Send you newsletters and offers or other communications about our products and services, such as special or promotional events;
  • Administer promotions, surveys, panels, or market research;
  • Detect, investigate, and prevent activities that may violate our policies or be fraudulent or illegal;
  • Optimize or improve the Websites, products, services, and operations; and
  • Perform statistical, demographic, and marketing analyses of users of the Websites and their usage patterns.

We may use the information from one portion of the Websites on other portions of the Websites, and we may combine information gathered from multiple portions of the Websites into a single record. We may also use or combine information that we collect offline or we collect or receive from third-party sources for many reasons, including to enhance, expand, and check the accuracy of our records. Additionally, information collected from a particular browser or device may be used with another computer or device that is linked to the browser or device on which such information was collected.

Disclosures of Your Information To Others

We disclose your personal information with third parties as described below.  In addition, we may disclose information that does not specifically and personally identify you, such as aggregate information to third parties, as permitted by applicable law. If we deidentify your personal information, we publicly commit to retain and use the deidentified personal information without attempting to reidentify the deidentified personal information.

Third-Party Service Providers:  We engage third-party service providers to perform functions on our behalf such as: hosting, technical integration, analytics, customer service, and fraud protection.  For example, we use third parties to process payments made to us.  These third parties may have access to your personal information when needed to perform their functions.

Business Partners:  We may disclose your personal information for our legitimate business purposes, such as:

  • Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with certain specifications and standards;
  • Helping to ensure security and integrity to the extent the use of personal information is reasonably necessary and proportionate for these purposes;
  • Debugging to identify and repair errors that impair existing intended functionality;
  • Undertaking internal research for technological development and demonstration; or
  • Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.

Joint Marketing: We may enter into joint marketing agreements with non-affiliated financial institutions.  Under such agreements, we may disclose your personal information, including your name, contact details, and transaction history, with these partners to offer products or services that may be of interest to you.  We ensure that all partners adhere to strict confidentiality and data protection standards, using your information solely for the intended purposes.

Sale, Assignment, or Change of Control:  We may change our ownership or corporate organization while providing the Websites.  We may transfer to another entity or its affiliates or service providers some or all information about you in connection with, or during negotiations of, any merger, acquisition, sale of assets or any line of business, change in ownership control, or financing transaction.  Under such circumstances, we will request the acquiring party to follow the practices described in this Privacy Policy with respect to previously collected information.  Nevertheless, we cannot promise that an acquiring party or merged entity will have the same privacy practices or treat your information the same as described in this Privacy Policy.

Law Enforcement, Legal Process, and Emergency Situations:  We may also use or disclose your personal information if required to do so by law or on the good-faith belief that such action is necessary to: (a) conform to applicable law or comply with legal process served on us or the Websites; (b) protect and defend our rights or property, the Websites, or our users; or (c) act to protect the personal safety of us, users of the Websites, or the public.

Other Third Parties for Our Legitimate Business Purposes: We may disclose your personal information to other third parties for our legitimate business purposes unless otherwise prohibited by applicable law, including with your consent or authorization.

Your Choices Regarding Promotional Communications

When you create an account through the Websites or sign up for certain communications, you are required to provide us with an accurate e-mail address through which we may contact you.  Such registrations or requests through the Websites constitute your express acknowledgment that we may use your e-mail address to communicate with you about product or service offerings from us and our selected partners.  While you cannot opt-out of receiving notifications and other communications regarding your account or your transactions, you can opt-out of receiving promotional and other marketing emails from us by using the “unsubscribe” feature in our marketing e-mails.

Cookies and Tracking Technology

Like many websites, we use tracking technologies such as cookies, web beacons, and similar technologies to record your preferences and track the use of the Websites.  We may also use these technologies to monitor traffic and improve the Websites.

Some content or applications on the Websites may be served by unaffiliated third parties.  We do not control these third parties’ tracking technologies or how they may be used.  We are not responsible for the content or privacy practices on any website not operated by us to which the Websites link or that link to the Websites.

Your browser or device may include “Do Not Track” functionality.  Currently, we do not recognize “Do Not Track” signals. Our information collection and disclosure practices, and the choices that we provide to visitors, will continue to operate as described in this Privacy Policy, whether or not a Do Not Track signal is received.

Online Tracking Choices:  You may also have choices to limit some tracking mechanisms that collect information when you use the Websites.  Many web browsers automatically accept cookies, but you can usually modify your browser’s settings to decline cookies if you prefer.  If you choose to decline cookies, certain features of the Websites, including the Websites themselves, may not function properly or remain accessible to you.  In addition, you may also render some web beacons unusable by rejecting or removing their associated cookies.  Note that if you choose to remove cookies, you may remove opt-out cookies that affect your advertising preferences. To learn more about cookies and your ability to opt-out of certain advertising cookies, please visit the Digital Advertising Alliance here or the Network Advertising Initiative here or here (for mobile devices).

 

We use Google Analytics, a web analytics service provided by Google, Inc., on the Websites. Google Analytics uses cookies or other tracking technologies to help us analyze how users interact with and use the Websites, compile reports on the Websites’ activity, and provide other services related to the Websites’ activity and usage.  The technologies used by Google may collect information such as your IP address, time of visit, whether you are a return visitor, and any referring website.  The Websites do not use Google Analytics to 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. 

How We Secure Your Information

We maintain safeguards to protect your personal information.  However, no system is completely secure or error-free.  We do not, and cannot, guarantee the complete security of your personal information.  You can help protect the privacy of your own information by using encryption and other techniques to prevent unauthorized interception of your personal information.  You are responsible for the security of your information that you transmit to us or view, download, or otherwise access when using unencrypted, public, or otherwise unsecured networks. 

Other Important Information

Users Outside of the United States:  If you use the Websites outside of the United States, you understand and consent to the transfer of your personal information to, and the collection, processing, and storage of, your personal information in the United States and elsewhere.  The laws in the United States and these countries regarding personal information may be different than the laws of your state or country. We reserve the right to restrict your access to the Websites when you are located in jurisdictions outside of the United States.

California Privacy Rights, California Consumer Privacy Act

This section supplements the other sections of this Privacy Policy.

If you are a California consumer, you may have certain rights with respect to the collection, use, disclosure, and processing of your “Personal Information”, as defined by the California Consumer Privacy Act (CCPA). We reserve the right to limit these rights where permitted under applicable law, including where these rights are not available based on your state of residence, your identity cannot be reasonably verified, or to the extent your rights adversely affect the rights and freedoms of others. To exercise any of the rights below, please contact us via the contact information below. Only you, or a person that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information.

Collection of Personal Information

In the preceding 12 months, we may have collected any of the personal information described in this Privacy Policy, including the following categories of Personal Information about you when accessing the Websites, using our services, or contacting ACA: identifiers, Internet or electronic network activity information, geolocation, commercial information, audio information (e.g., call recordings), professional or employment-related information, and sensitive Personal Information (e.g., driver’s license number and Social Security number).

Categories of Sources from which Personal Information is Collected

The sources from which we may collect your Personal Information include the following categories: directly from you when you provide it to us, from your interactions with our Website, information we receive from third parties such as our service providers, and other third parties.

Business or Commercial Purposes for Which Personal Information is Collected

We may collect and use your Personal Information for any of the following business or commercial purposes, including: to perform services, including maintaining or servicing accounts, providing customer service, verifying customer information, processing payments, or providing similar services; to operate, understand, optimize, develop, or improve our Website, applications, products, services, and operations; to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; to debug in order to identify and repair errors that impair existing intended functionality; and to investigate and prevent activities that may violate our policies, and other commercial purposes.

Categories of Third Parties with whom Personal Information is Disclosed

We may disclose your Personal Information to any of the following third parties for any of the business or commercial purposes described in this Privacy Policy, including: affiliates, dealers, analytics providers, service providers, IT vendors, government entities, operating systems and platforms, advertising networks, social networks, and data brokers.

Third Parties with whom Personal Information is Shared or Sold

We do not sell your Personal Information to third parties for money.  However, our use of certain analytical and tracking tools may constitute the sale or sharing of information under the CCPA. For the purposes of this section, “share” means sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, your Personal Information by us to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration, including transactions between us and a third party for cross-context behavioral advertising for the benefit of ACA in which no money is exchanged.

In the preceding 12 months, we have not knowingly sold or shared (as such term is defined in the CCPA) Personal Information about California consumers under 16 years of age. We also do not use your sensitive Personal Information to infer characteristics about you.

Right to Know About Personal Information Collected, Disclosed, Sold, or Shared

You may have the right to request ACA to provide you with the Personal Information it collects, uses, and discloses about you to third parties. There are two types of Right to Know requests you can make:

  1. Right to Know (Abbreviated Request): If you make a Right to Know (Abbreviated Request), you will receive the following information about you:
    1. Categories of Personal Information collected,
    2. Categories of sources from which that information was collected,
    3. The business or commercial purpose(s) for which the information was collected,
    4. The categories of third parties to whom ACA sold, shared, or disclosed the category of Personal Information for a business purpose, and
    5. The business or commercial purpose for which ACA sold, shared, or disclosed the category of Personal Information.
  2. Right to Know (Specific Pieces of Information Request): If you make a Right to Know (Specific Pieces of Information Request), you will receive the following information about you:
    1. Specific pieces of Personal Information collected about you, which may include a copy of all Personal Information we are processing or have processed (subject to exceptions as permitted by applicable law).

 

This information will be provided to you free of charge, unless ACA determines that your request is manifestly unfounded or excessive.  You may request this information twice in a 12-month period.

Right of Deletion

You may have the right to request that ACA and our service providers delete any Personal Information about yourself that ACA has collected from you or otherwise maintains.

Right to Correct 

You may have the right to request that ACA and our service providers correct any inaccurate Personal Information about yourself that ACA maintains.  When correcting inaccuracies, ACA will take into account the nature of the Personal Information and the purpose for processing the Personal Information.

Right to Opt-Out of the Sale or Sharing of Personal Information

As noted above under “Third Parties with whom Personal Information Is Shared or Sold,” we do not sell your Personal Information to third parties for money. However, the use of certain analytical and tracking tools may constitute the sale or sharing of information under the CCPA. You may have the right to opt-out of the sale or sharing of your Personal Information by clicking on the link on the homepage of our Websites entitled “Do Not Sell or Share My Personal Information.” Such opt-out right may also be available through an opt-out preference signal.

Right to Limit Use and Disclosure of Sensitive Personal Information 

You may have the right to request that ACA limit the use and disclosure of your sensitive Personal Information to only those purposes specifically authorized under California law.  At this time, we do not process or disclose your sensitive Personal Information for purposes that are not specifically authorized under California law.  Should this change, we will notify you and provide you with an opportunity to limit our processing of your sensitive Personal Information.

Other Privacy Rights, including Right to Appeal

Under the CCPA, you may have additional privacy rights, including the right to appeal any action we take in response to your privacy requests by contacting us using the same method used to submit your original request, as outlined below.

Submitting Requests

If you have a registered account with us, you can update your account information through the account settings page within the Websites.

You can submit your request to exercise any of the rights described above regarding your Personal Information by calling us toll-free at 866-544-3430.  You may also submit a request by emailing us at [email protected].

Please provide detail about what you are requesting, as well as your name, the last 4 digits of your ACA account number, and the last 4 digits of the VIN for the vehicle relating to your ACA account.  Please note that we may not be able to delete your Personal Information without also deleting your user account. You will not be permitted to examine the Personal Information of any other person or entity, unless you have been appointed a legal representative or Authorized Agent of the person.  We may not accommodate a request to change or delete Personal Information if we believe doing so would violate any law or legal requirement, cause the information to be incorrect, or if compliance with such request is not required under applicable law. If you disagree with our decision in response to any such request, you may appeal the decision by contacting us at [email protected].  Please note that these rights are not available to consumers in all states.

Verifying Requests

ACA must verify that the person making the request is the California Consumer about whom the request relates to or an Authorized Agent of the consumer in order to process the request.  To verify a California Consumer’s identity, we may request up to three pieces of Personal Information about you when you make a request to compare against our records.  We cannot respond to your request or provide you with Personal Information if we cannot verify your identity. Making a verifiable consumer request does not require you to create an account with us.  We will only use Personal Information provided in your request to verify your identity and will delete any information you provide for such verification purpose after processing the request.  ACA reserves the right to take additional steps as necessary to verify the identity of California Consumers where we have reason to believe such additional verification is necessary, including if we believe a request may be fraudulent.

Authorized Agent

You may choose a person that you authorize to act on your behalf to submit your requests (“Authorized Agent”).  If you choose to use an Authorized Agent, ACA requires that you provide the Authorized Agent with written permission to allow them to submit your request and that you verify your identity directly with ACA. Failure to do so may result in ACA denying your request. A parent or legal guardian may exercise these rights on behalf of a child for whom the requestor has legal responsibility.

Right to Equal Service

ACA will not discriminate or retaliate against you because you exercised any of your rights, including, but not limited to, by:

  • Denying goods or services to you.
  • Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties.
  • Providing a different level or quality of goods or services to you.
  • Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Opt-Out Preferences Signals 

We recognize the Global Privacy Control.  Your browser must be able to support the Global Privacy Control for us to recognize your opt-out preference signal.

We do not share, as such term is defined in the CCPA, your Personal Information with third parties for the third parties’ direct marketing purposes. 

Retention of your Personal Information 

We retain the information collected pursuant to this Privacy Policy for the duration of time required to maintain our business relationship with you and for as long as is required to satisfy the retention requirements of any applicable data retention laws or regulations.  Personal Information that is no longer needed for its stated purpose will be destroyed, erased, or made anonymous.

We take appropriate measures to ensure that your information is processed and disposed of in a manner that maintains its confidentiality.  All Personal Information disposal procedures, including the disposal of computerized data storage devices, are designed to ensure the complete destruction of Personal Information and eliminate the risk of subsequent unauthorized access or disclosure. 

Questions or Report a Problem

For questions about our Privacy Policy or the Websites, to make choices about receiving promotional communications, or to update your personal information, you can contact us at [email protected].