Revised April 26, 2016

At ECP Incorporated ("ECP"), we want you to be fully informed about what information we collect, why we collect it, and what we do with it.  Please take a moment to review this Privacy Policy carefully.

Information We Collect About You

We collect information to provide our products and services to you, and to improve them for you and all of our customers, including the following types of information:

• Who you are and how we can contact you;
• Details about your vehicle;
• Details about the purchase of your vehicle (like the seller, price, mileage at sale, purchase price, financing arrangements);
• Date our Product was applied and the price paid for the Product; and
• Details about the warranty and any warranty claims.

We collect information in the following ways:

• Information you give us directly. When you sign up for, or purchase, a product or service from us, we'll ask you for personal information, like your name, mailing address, email address, telephone number, and information necessary to provide you with the product or service you are purchasing, or when we receive information from you verbally by phone or in writing by email or letter, including when you file a claim.
   
• Information you give us indirectly.  When you complete warranty registration forms, service contract forms, or other ECP forms provided by car, marine and powersports dealers, we receive the information you have provided.
   
• Information we receive from companies that help us provide you with products and services. We receive information from third parties we hire to examine your vehicle and report back to us in relation to warranty or service contact claims you might make and from repair shops that perform repairs at our expense in relation to claims you have made with us.
   
• Information we receive from our business partners and associates. We receive information from business partners and associates in accordance with the consent you have provided them.

How We Use Information We Collect

We use the information we collect to provide, maintain, protect and improve our products and services, to develop new products and services, and to protect us and our customers. For example, we use the information to:

• Process and administer the limited warranty associated with our appearance protection product;
• Process and administer your service contract;
• Provide the products and services you request (fulfillment of requests for additional consumer kits, warranty transfers to subsequent owners, etc.), or to otherwise operate our business;
• Evaluate the effectiveness of our customer responsiveness and improve our products and services (complaint management system);
• Respond to your questions or inquiries;
• Carry out other purposes that are disclosed to you and to which you have consented; and comply with legal or regulatory requirements (For example, we are required by law in several states to retain a registration record for each warranty issued in connection with a protection product purchase for the term of the warranty, and for a specified time thereafter).

We will ask for your consent before using information for a purpose other than the types of purposes described in this Privacy Policy.

Information We Share

We do not sell your personal information. We also do not share information with third parties for marketing purposes, and we do not use information internally for marketing purposes.

We may disclose your information to service providers, business partners, and associates who help us to provide our products and services, including, but not limited to:

• Third Party Ancillary Product Providers;
• Third Party Vehicle Damage Appraisers;
• Third Party Repair Facilities;
• Agents and Distributors of ECP;
• Motor Vehicle Dealerships;
• And other services providers and business partners and associates.

We need to share information with our service providers, business partners, and associates in order to ensure the proper registration of contracts, to administer claims, and to process requests for contract cancellations, and general financial management, control and collection.  We share only the information necessary to achieve the purpose for which we are sharing the information.

We may also disclose information:

• In accordance with your express instructions or consent, or the express instructions or consent of your authorized representative;
• To carry out transactions requested by you;
• To collect or compile information from or about you with our service providers, business partners and associates for the purposes of facilitating the provision of their products and/or services to you;
• For invoicing and debt collection purposes;
• To troubleshoot warranty registration issues;
• To investigate consumer complaints;
• To notify selling dealers that a claim has been paid to one of their customers;
• To attorneys for the purpose of resolving consumer complaints or litigation, whether actual or anticipated;
• If we believe that it is reasonably necessary to comply with legal process (such as a court order, subpoena, search warrant, etc.) or other legal requirements of any governmental or regulatory authority;
• If it would potentially lessen our liability in an actual or potential lawsuit or investigation, or to conduct investigations of possible breaches of law or agreements;
• To bring legal action against someone who may be violating an agreement they have with us; or,
• If it is necessary to protect our or others’ rights or property.

We have entered into contractual agreements with our service providers, business partners and associates to require them to protect the information we provide to them.

We reserve the right to transfer any information we have about you in the event that we merge with or are acquired by a third party, or should any such transaction be proposed.

Information Security

We maintain physical, electronic, and organizational safeguards to protect the information we have collected. [“Information” or “Personal information”] may only be accessed by persons within our organization, or our third party service providers, or business partners and associates, who require such access to carry out the purposes indicated in this policy, or otherwise disclosed to you. Personal information we collect is maintained at our corporate headquarters in Woodridge, IL, USA.  We review our policies and practices and make adjustments as necessary to ensure the safety of this information.

Retention of Information

ECP has established internal policies for the retention of customer data for as long as reasonably necessary to fulfill the purposes for which it is collected or to meet legal requirements, including warranty and service contract registrations, claims history, and related information.  Your information will be retained for at least the period of time designated in our data retention policy.  

We are also required by law in some jurisdictions to retain information about you for a specified period of time. When we dispose of your data, we will do so in a way that prevents it from being disclosed to unauthorized parties.

Children

Our services are not directed at minors or intended to be used by minors.  Do not send any information about yourself to us if you are under the age of majority in your jurisdiction.  In addition, if we learn that a person under the age of majority in his or her jurisdiction has submitted information to us, we will attempt to delete this information.  If you have reason to believe that we may have accidentally received information from a person under the age of majority in his or her jurisdiction, please contact us immediately at ecp_compliance@ecpinc.net.

Your California Privacy Rights

If you are a California resident, you may request that we provide to you:

• A list of the categories of personal information about you that ECP has disclosed to third parties for the third parties’ direct marketing purposes during the calendar year preceding your request;
• The names and addresses of such third parties; and,
• If the nature of the third parties’ business cannot reasonably be determined from their names, examples of the products or services marketed, if known to ECP, sufficient to give you a reasonable indication of the nature of the third parties’ business.

To submit your request, please email ecp_compliance@ecpinc.net.  While we are making this disclosure to comply with California law, ECP does not provide information to third parties for marketing purposes.

International Customers

By purchasing our products, using our services, or providing your information to us, you consent to the transfer of your personal information to the United States, and our handling of your information in accordance with applicable U.S. requirements, which may differ from those in the jurisdiction in which you live.  As a result, this information may be subject to access requests from governments, courts, or law enforcement in the United States according to its laws.

Canadian Customers

Access and Rectification

You have a right to request access to your personal information and to request a correction to it if you believe it is inaccurate.  If you have submitted personal information to us and would like to have access to it, or if you would like to have it removed or corrected, please contact us using the contact information provided below.  We will use reasonable efforts to comply with your request.  However, in some cases, we may not be able to allow you to access personal information in certain circumstances, for example if it contains personal information of other persons, or for legal reasons.  In such cases, we will provide you with a reasonable explanation of why it is not possible to grant access to your personal information.

Changes to this Privacy Policy by ECP

ECP reserves the right to change or modify this Privacy Policy at any time and in our sole discretion, and we will post the new Privacy Policy on our website at www.ecpinc.net on or in advance of the date it becomes effective.  You agree to the new Privacy Policy by your continued access to and/or use of our site and/or your continued use of our products and/or services after any such changes.  Please periodically review this privacy policy so that you know what personal information we collect, how we use it, and with whom we may share it.

Contacting ECP

If you have any questions, comments, or concerns about our information practices or this Privacy Policy, please email us at ecp_compliance@ecpinc.net or write to our Director of Compliance at:

ECP Incorporated

Compliance Department

11210 Katherine’s Crossing, Suite 100

Woodridge, IL 60517

Revision Number 1