Privacy Policy

[insert logo]

Privacy Policy

Effective Date: [insert launch date]

This Privacy Policy covers High Octane Marketplace, LLC’s (“Company,” “we,” “us,” “our”) policies on the collection, use, and disclosure of personally identifiable and other personal information (as defined by applicable law) (collectively referred to as “Personal Information”) in connection with your access and use of the txt4parts.com website and related mobile applications (collectively the “Platform”) and the software and services made available through the Platform.

  1. Personal Information Collected by Company 

Accessing the Services. To use the services offered through the Platform, Users will be required to provide a zip code to find local vendors to respond to any parts request or orders submitted by you through the Platform.  Users will also be required to input a mobile number to route messages to vendors who have registered accounts with Company to provide services through the Platform (hereinafter “Vendors”). 

Opt-In Text Messaging. To receive text messages from Company or Vendors in your area, as applicable, you must opt-in to the text messaging services by signing up through the Platform. When you input your cellphone number, Users will receive a security code by text to authenticate requests. Upon authentication, Users will then be able to receive text(s) containing information relating to your parts request and participating Vendors in your area. Vendor communications, invoices and payments will be transacted through the Platform via a User’s mobile number.  When a User provides their opt-in consent through their mobile phone for marketing-related communications, Company may also utilize mobile phone numbers to communicate promotional offers.   Users can unsubscribe at any time by texting “STOP” to any text message sent through the Platform.

Order Information.  When you place an order through the Platform, Company will request input of a User’s name, billing address, payment information (including credit card numbers), and mobile number to facilitate processing, fulfillment and confirmation of requested services.  

Cookies.  Company utilizes cookie technology to gather information on internet use in order to serve you more effectively. As described in Section 2, Company also utilizes third party analytics services which may also use tracking cookies to provide information about the use of our Platform. Users can set their browser to remove or reject cookies utilized by the Platform.

Web Beacons/Log Files & Cookies.  Company utilizes web beacon, log files, and cookie technology to gather information on internet use in order to serve you more effectively.  Cookies are data files that are placed on your device or computer an often include an anonymous unique identifier. “Log-Files” track actions occurring on the Platform and collect data including a user’s IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.  “Web beacons” “tags” or “pixels” are electronic files used to record information about how you browse the Platform.  As described in more detail below, Company also utilizes third party analytics services which may also use tracking cookies to provide information about the use of our  Platform. Users can set their browser to remove or reject cookies utilized by the Platform.  Users may opt-out from receiving targeted advertisements by visiting the (1) Network Advertising Consumer Opt-Out page, (2) Digital Advertising Alliance Opt-Out page, and/or (3) the opt-out provisions pertaining to the applicable advertising services/retargeting provider.

  1. Personal Information Disclosed by Company

COMPANY DOES NOT SELL PERSONAL INFORMATION.  HOWEVER, PERSONAL INFORMATION IS COLLECTED FOR LEGITIMATE BUSINESS PURPOSES AND PROCESSED BY SERVICE PROVIDERS WHO HAVE CONTRACTED WITH COMPANY TO PROVIDE THE FOLLOWING PLATFORM-RELATED SERVICES: 

User Authentication. Company utilizes authorization services to facilitate secure access to the services.  Authentication will require a User to input a one-time authentication code sent to a User’s email or mobile number to authenticate log-in and/or transaction requests. Please see the Twilio Privacy Policy for more information.

Google Analytics.   Company utilizes Google Analytics to access anonymized and/or pseudo anonymized data to help us understand how our services are used.  Google Analytics is a web analytics tool that helps us understand how users engage with our Platform, so that we can review and improve our services.  Google Analytics provides a report to us with website trends without identifying the Personal Data of individual users.  Please see Google’s Data Privacy and Security Policy. However, if you decide to withdraw your consent to such data collection, you may opt-out by installing Google Analytics Opt-out Browser Add-on.

Order Processing.   When a User places an order, order information in shared with the applicable Vendor in order to provide the requested order.  A User’s mobile number is not shared directly with the Vendor, but rather messaging is routed through the Platform to facilitate communications via Twilio’s integrated API’s.  Please see the Twilio Privacy Policy for more information.

Payment Processing Information. Company does not itself store debit or credit card information on its servers. Company utilizes a third party payment processors to manage and process payments in order to guarantee the security of your information.  For more information on these processors, please see the Stripe Privacy Policy for additional information

Image Analytics.   Company utilizes Google Cloud’s Vision API to assign labels to images uploaded by Users to enable it to quickly classify into predefined auto-part categories. Please see the Google Privacy Policy for additional information. 

Hosting Services. Company hosts user and services data through Amazon Web Services. Users should click on the Amazon hyperlink for more information.

Cloud Services.  Company utilized MongoDB Atlas to host and manage Platform related data and documents  in the cloud.  User data is processed by MongoDB to perform the services in accordance with its Data Processing Terms.

Google AdConversion Tracking.  Company uses Google AdConversion Tracking to track a User’s action after a User interacts with a Company ad by placing a conversion tracking tag, or code snippet, to the Platform. When a User clicks on Company’s ad from Google Search or selected Google Display Network sites, or when a User views Company’s video ad, a temporary cookie is placed on User’s computer or mobile device. When a User completes the action (for example, makes a purchase, initiating  a transaction, engaging in a communication with Company or a Vendor),  Google AdConversion will  record a conversion.  This analytical data will help Company with personalized, retargeting of its ads and to assess the success of its marketing campaigns. Users can block customizes ads from their device/browser at Google AdSense Choices. Users can also install Google’s DoubleClick Opt-Out Add On to opt-out of personalized ads.

Internal Search Engine Analytics.  Company utilizes Qbox.io, Elastic Search, a hosted solution for implementing internal site search and data exploration. Qbox.io only processes personal data input by Company for purposes of providing the services.  Please see the QBox.io Privacy Policy for additional information.

Other Potential Disclosures. Personal Information may be disclosed to serve our legitimate business interests as follows: (1) as required by law, such as to comply with a subpoena, or similar legal process, (2) if Company is involved in a merger, acquisition, or sale of all or a portion of its assets, (3) to investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (4) enforce our agreements with you, and/or (5) investigate and defend ourselves against any third-party claims or allegations. We will use commercially reasonable efforts to notify you about law enforcement or court ordered requests for data unless otherwise prohibited by law.

  1. Compliance with the Children’s Online Privacy Protection Act, CCPA and Other Privacy Regulations Relating to Children

Company does not knowingly collect Personal Information from anyone under the age of 18.  If a parent or guardian becomes aware that his or her minor child as defined by applicable privacy laws has provided Personal Information without their consent, he or she should contact Company at legal@txt4parts.com 

Company will delete such Personal Information from our files within a commercially reasonable time, but no later than required under applicable law. 

  1. Retention of Personal Information 

Unless erasure is otherwise requested by a customer, Company will retain account and purchase data as long as it is necessary to provide services our customers.  When a customer’s account is terminated or closed upon request, Personal Information collected through the Platform will be deleted in accordance with applicable law. Personal Information obtained from Platform visitors will be maintained as long as it is necessary to provide requested communications and information-based services or until a visitor exercises the right to opt-out of requested communications or information-based services.  Anonymized and pseudo-anonymized data will be retained as long as Company determines such data is commercially necessary for its legitimate business interests.

  1. YOUR CALIFORNIA PRIVACY RIGHTS

Company does not sell and will not sell your Personal Information.   Company launched the Platform effective [insert date] and did not collect any Personal Information in the last 12 months.  Upon launch, Company will collect and process information in accordance with the disclosures set forth in Sections 1 and 2 of this Privacy Policy.  California Consumers may contact Company to exercise the following rights pursuant to the California Consumer Privacy Act of 2018, Civil Code sections 1798.100 et seq. (“CCPA”): 

  1. Request Company Disclose At No Charge

• Specific pieces of personal information it has collected about you; 

• categories of Personal Information collected, used, and/or disclosed about you;

• categories of sources from which Personal Information is collected;

• business and/or commercial purposes for collecting and disclosing your Personal Information; 

• categories of third parties with whom your Personal Information has been disclosed/shared; and

Right to Know Requests can be submitted to Company by email at legal@txt4parts.com  

  1. Request Company to Delete At No Charge:

Except as exempted pursuant to CCPA 1798.105, to request Company delete Personal Information.

Deletion requests can be submitted to Company be email at legal@txt4parts.com or by mail to Company at 100 Cornwall Road, Suite 100, Monmouth Junction, NJ 08852 or by email at legal@txt4parts.com 

  1. Verified Request Process

Company will verify all consumer requests prior to taking any action in response to such request.  For consumers that maintain an account with Company, it may verify the identity of the consumer making the request by either matching with the account information on file or through existing account authentication credentials.  For non-account holders, Company shall verify to a reasonably high degree of certainty, including matching at least three pieces of consumer personal information with that maintained by Company and/or if necessary, by a signed statement by consumer under penalty of perjury that the requestor is the consumer for which personal information is sought. 

Under the CCPA, you may exercise these rights yourself or you may designate an authorized agent to make these requests on your behalf.  Authorized agents must demonstrate they have written authorization from you to make requests on your behalf. Company may additionally require the consumer to confirm their identity and verify the authorized agent’s permission before complying with any request.

  1. Non-Discriminatory Treatment

You have the right not to receive discriminatory treatment for exercising any rights conferred by the CCPA.   Company shall not discriminate against a consumer for exercising any rights under the CCPA, including, but not limited to, (1) denying goods or services, (2) charging different prices or rates (including discounts/penalties) that is not directly related to the value provided to Company for the Personal Information, or (3) suggesting Consumer will receive a different rate/price or different level of quality of goods/services 

  1. Your California Privacy Rights under California Civil Code Section 1798.83 & Business and Professions Code Section 22581 

California law permits Consumers to request and obtain from once a year, free of charge, certain information about their Personally Identifiable Information (“PII”) (as defined by California law) disclosed to third parties for direct marketing purposes in the preceding calendar year (if any). If applicable, this information would include a list of the categories of PII that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. 

In addition, a business subject to California Business and Professions Code Section 22581 must allow California residents under age 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted. Your request should include a detailed description of the specific content or information to be removed. Please be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

  1. Accessibility of this CCPA Policy. 

You can download and print a copy of this Privacy Policy here

  1. Company’s Security Policy 

We have implemented reasonable administrative, technical and physical security measures to protect Personal Information against unauthorized access, destruction or alteration. 

Company utilizes only PCI-DSS compliant third-party payment processors to ensure the security of your personal information. 

  1. Response To “Do Not Track” Signals

“Do Not Track” is a feature enabled on some browsers that sends a signal to request that a website disable its tracking or cross-website user tracking. At present, the Platform does not respond to or alter its practices when a Do Not Track signal is received. 

  1. Notification of Changes to Privacy Policy 

If we make material changes to our Privacy Policy, we will notify you by (a) changing the Effective Date at the top of the Privacy Policy, or (b)  adding a banner/notification to the Platform itself.  

  1. Contact Us

If you have any questions regarding your Personal Information or about our privacy practices, please contact us at:  High Octane Marketplace, LLC. Attention: Privacy at 100 Cornwall Road, Suite 100, Monmouth Junction, NJ 08852 or by email at legal@txt4parts.com

This Privacy Policy was last updated on January 1, 2021