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We use cookies and share information about your site visit to personalize
content and ads, provide social media features and analyze traffic using tools
such as Google Analytics. We do not sell your personal information. You can view
our privacy notice, cookie policy and how to exercise your rights on our Privacy
Policy Page.
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PRIVACY POLICY


DDI TECHNOLOGY IS AN IAA, INC. COMPANY

Effective: February 2020

Your privacy is important to Insurance Auto Auctions, Inc. (“IAA,” “we,” or,
“us”). We developed this Privacy Policy to provide you with information on how
we process your personal data when you visit our websites or our mobile
applications (“apps”), including when you complete forms, and when you utilize
our other offerings (e.g., newsletters, discussion lists, and announcement
lists). Throughout this Privacy Policy, our websites and apps may be jointly
referred to as our “Sites.” This Privacy Policy applies only to Sites on which
this Privacy Policy is posted.

“Personal data” is information relating to an identified or identifiable natural
person.

CATEGORIES OF PERSONAL DATA PROCESSED BY IAA

Personal data that is processed when you communicate with IAA: When you interact
with our representatives via email, telephone, online, on social media, or in
person, we may collect personal data, including your name, email address, phone
number, branch, stock number, and service category. We also may create event
logs that are useful in diagnosing server and app performance-related issues,
and capturing information relating to support or service issues. To improve
customer service, subject to applicable laws, we may also record and review
conversations with customer support representatives, and analyze any feedback
provided through voluntary surveys. With your consent, our customer support
representatives may log in to your IAA account, if appropriate, to reproduce an
issue and help troubleshoot and resolve your issue. As a security precaution,
our customer support representatives will issue you a password reset after being
asked to log in to your customer account. If you contact us on one of our social
media platforms, your interactions with us are governed by this Privacy Policy,
as well as the Privacy Policy of the social media platform you use.

 * Purposes and Legal Grounds: We use this information to respond to your
   comments and questions, provide you with customer service, and to monitor and
   enhance the quality and types of customer service we provide to our
   customers. The legal ground for processing this information for these
   purposes is IAA’s legitimate interests in providing quality support and
   customer service. The legal ground for logging in to your IAA account, if
   appropriate, to help troubleshoot and resolve your issue is your consent,
   which you may withdraw at any time.

Personal data that is processed when you register for and use an IAA Account: We
offer Free Accounts, Public Buyer Accounts, and Licensed Business Buyer
Accounts. When you create and use your IAA account, you will be asked to enter
your email address or Login ID and password. In addition, we collect the
following information when you register for an IAA Account:

 * Free Accounts. When you register for a free account, we collect your name and
   email address.
 * Public Buyer Accounts. When you register for a Public Buyer Account, we
   collect your name, date of birth, street address, phone number, fax number,
   cell number, IP address, photocopy of government issued photo ID with
   signature (ID), ID number, ID state or country, ID expiration date.
 * Licensed Business Buyer Accounts. When you register for a Licensed Business
   Buyer Account, we collect your name, company name, business license address,
   mailing address, phone number, fax number, cell number, IP address, photocopy
   of government issued photo ID with signature (ID), ID number, ID state or
   country, ID expiration date, business license (BL), BL number, BL effective
   date, BL expiration date.Additional Bidders. When additional bidders are
   added to a Licensed Business Buyer Account, we will also collect the account
   owner’s name, company name, Buyer Number, and the new bidder’s name,
   relationship to company (employee (W-2) or agent/broker/representative),
   photocopy of the new bidder’s government issued photo ID with signature (ID),
   ID number, date of birth, ID state or country, ID expiration date, phone
   number, cell number, email address, and mailing address.
 * Purposes and Legal Grounds:
   * All Accounts. IAA processes your email address or Login ID and password for
     the purpose of enabling you to securely log in to your IAA account. The
     legal ground for processing this information for this purpose is IAA’s
     legitimate interest in protecting the security of your IAA account. IAA may
     also process your email address, name, and mailing address for market
     research purposes, or for sending you information about your IAA account,
     which may include material changes to this Privacy Policy. The legal ground
     for processing this information for these purposes is IAA’s legitimate
     interest in conducting market research to improve our products and
     services, and IAA’s legitimate interest in providing you with information
     about your IAA account.
   * Free Accounts. IAA processes your name and email address or Login ID and
     password for the purpose of permitting you to have a Free Account, which
     allows you to browse and search our nationwide inventory, add vehicles to
     your Watch List, attend auctions online as a non-bidding guest, manage
     email alerts and preferences, and for IAA’s internal recordkeeping
     purposes. The legal ground for processing this information for this purpose
     is IAA’s legitimate interest in offering and providing services to guests
     who are interested in reviewing our inventory and attending IAA auctions as
     non-bidding guests.
   * Public Buyer Accounts. IAA processes your name, date of birth, street
     address, phone number, fax number, cell number, IP address, photocopy of
     government issued photo ID with signature (ID), ID number, ID state or
     country, and ID expiration date for the purposes of verifying that you meet
     the requirements to upgrade to a Public Buyer Account, which provides you
     with a Buyer Number and permits you to browse and search our nationwide
     inventory, add vehicles to your Watch List, attend auctions online, manage
     email alerts and preferences, access public auctions, bid online, on site,
     and via proxy at IAA branches in certain states in the U.S., buy instantly
     via Buy Now, and for IAA’s internal recordkeeping purposes. We also may
     process your name, date of birth, and address for purposes of meeting our
     regulatory obligations. The legal ground for processing this information
     for these purposes is IAA’s legitimate interests in offering and providing
     services to Public Buyers; permitting Public Buyers to bid and make
     purchases; and complying with applicable legal requirements.
   * Licensed Business Buyer Accounts. IAA processes your name, company name,
     business license address, mailing address, phone number, fax number, cell
     number, IP address, photocopy of government issued photo ID with signature
     (ID), ID number, ID state or country, ID expiration date, business license
     (BL) type, BL number, BL state of issue, BL effective date, BL expiration
     date, and tax identification number (e.g., social security number or
     employer identification number) for the purpose of verifying that you meet
     the requirements to upgrade to a Licensed Business Buyer Account, which
     provides you with a Buyer Number and permits you to browse and search our
     nationwide inventory, add vehicles to your Watch List, attend auctions
     online, manage email alerts and preferences, access all auctions where your
     license permits you to bid, bid online, on site, and via proxy at IAA
     branches where your license permits you to bid, buy instantly via Buy Now,
     add bidders to your account, and for IAA’s internal recordkeeping purposes.
     We also may process your name, date of birth, and address for purposes of
     meeting our regulatory obligations. The legal ground for processing this
     information for these purposes is IAA’s legitimate interests in offering
     and providing services to Licensed Business Buyers; permitting Licensed
     Business Buyers to bid and make purchases; and complying with applicable
     legal requirements.
   * Additional Bidders for Licensed Business Buyer Accounts. IAA processes the
     Licensed Business Buyer Account owner’s name, company name, Buyer Number,
     and the new bidder’s name, relationship to company (employee (W-2) or
     agent/broker/representative), photocopy of the new bidder’s government
     issued photo ID with signature (ID), ID number, date of birth, ID state or
     country, ID expiration date, phone number, cell number, email address, and
     mailing address for purposes of verifying that the new bidder meets the
     requirements to act as an authorized bidder on a Licensed Business Buyer
     Account and for IAA’s internal recordkeeping purposes. We also may process
     the names, dates of birth, and addresses of the Licensed Business Buyer
     Account owner and the new bidder for purposes of meeting our regulatory
     obligations. The legal ground for processing this information for these
     purposes is IAA’s legitimate interests in permitting multiple bidders to
     make purchases on a Licensed Business Buyer Account; protecting the
     security of Licensed Business Buyer Accounts; and complying with applicable
     legal requirements.

Personal data that is processed when you register for and attend one of our
Tradeshows, Buyer Forums, or Buyer Seminars: When you register for and attend
one of our tradeshows or an industry tradeshow, Buyer Forums, or Buyer Seminars,
we may collect your name, telephone number, email address, Buyer Number, and the
topics upon which you would like to receive additional information.

 * Purposes and Legal Grounds: IAA processes this information for the purpose of
   planning for and hosting its tradeshows and industry tradeshows, Buyer
   Forums, and Buyer Seminars, and marketing IAA’s goods and services. The legal
   ground for processing this information for these purposes is IAA’s legitimate
   interest in effectively marketing IAA’s goods and services. IAA also
   processes this information for the purposes of sending you marketing
   communications and allowing our Marketing Alliance Partners (also known as
   Authorized Representatives and Licensed Brokers) to follow up with you (via
   email or telephone) to assist you with purchasing vehicles from IAA auctions,
   and making necessary transportation and shipping arrangements.
   * The general legal ground for processing this information for this purpose
     is IAA’s legitimate interest in providing our customers and our potential
     customers with marketing materials to effectively promote IAA’s products
     and services, and to follow up with potential customers who may need
     assistance purchasing vehicles from IAA auctions and arranging for
     transportation and shipping services.
   * If you provide your consent to receive marketing communications and allow
     our Marketing Alliance Partners (also known as Authorized Representatives
     and Licensed Brokers) to follow up with you (via email or telephone), the
     legal ground for processing your personal data for this purpose is your
     consent, which you may withdraw at any time.

Personal data that is processed when you allow IAA to access your mobile device
location: With your consent, we may access the location of your mobile device
for the purpose of offering you technology services, and monitoring and
enhancing customer experience and service.

 * Purposes and Legal Grounds: IAA processes your mobile device location in
   connection with geofencing technology services for the purposes of: (1)
   Identifying when you are close to an IAA auction location; (2) Sending you
   welcome messages when you arrive at an IAA auction; (3) Permitting you to
   avoid lines by electronically checking in at an IAA auction; (4) Sending you
   marketing messages tailored to your location; and (5) Identifying how many
   auction attendees have the IAA buyer app enabled at an IAA auction. The legal
   ground for processing this information for these purposes is your consent,
   which you can withdraw at any time by adjusting your mobile device settings
   within the IAA app.

Personal data that is processed when you search for, bid on, and purchase
vehicles: When you search for, bid on, and purchase vehicles through our Sites,
we receive information concerning your searching, bidding, and purchasing
practices (e.g., vehicle segment, actual cash value (ACV), vehicle class,
mileage, vehicle age). If you provide your consent, we may access the microphone
on your mobile device to allow you to use voice controls when searching for
vehicles. If you provide your consent, we may access the camera on your mobile
device, so you can scan vehicle identification number (VIN) barcodes and request
information about particular vehicles.

 * Purposes and Legal Grounds:
   * We process your searching, bidding, and purchasing history for the purpose
     of better understanding your preferences, so we can identify vehicles that
     may be of interest to you, optimize your search results, and send you
     marketing information based on your vehicle preferences. The legal ground
     for processing this data for these purposes is IAA’s legitimate interest in
     understanding your vehicle preferences, so we can identify vehicles that
     are likely to be of the most interest to you, and our legitimate interest
     in reducing the number of marketing communications sent to customers by
     selecting which customers receive a particular marketing communication
     rather than sending every marketing communication to every customer.
   * We process statements you make through the microphone on your mobile device
     for the purpose of allowing you to conduct vehicle searches using voice
     commands. We process the images you take using the camera on your mobile
     device for the purpose of identifying VIN barcodes and providing you with
     information about particular vehicles. The legal ground for processing this
     data for these purposes is your consent, which you can withdraw at any time
     by adjusting your mobile device settings within the IAA app.

Personal data that is processed when you purchase a product or pay your annual
account fee: When you purchase a product from IAA or pay your annual account
fee, we collect your name, email address or Login ID, password, and Buyer Number
to identify your account. For purchases, we use a shopping cart feature that
safeguards your order information using industry standard SSL (Secure Socket
Layer) encrypted connections. SSL encodes the information transferred between
you and the server, rendering it unreadable to anyone trying to intercept the
information. We use electronic payment vendors to process credit card data and
to utilize I-Pay, which enables qualified buyers with company check writing
privileges to make payments directly from a U.S.-based bank account via the
Internet. When you use a payment card to make a purchase or pay your annual
account fee, our third-party payment processor, BluePay Processing, processes
your payment card information. BluePay’s Privacy Policy, which addresses its
privacy practices, can be found on its website www.bluepay.com. If you authorize
your bank to release your information to IAA (to obtain check-writing
privileges), we may collect certain banking information, including your bank
name, bank account number, bank address, date bank account opened, average
balance of bank account, non-sufficient funds history, and whether your account
has been maintained in an excellent, satisfactory, or other manner. If you
decide to transport a vehicle using IAA Transport, we also collect your shipping
address.

 * Purposes and Legal Grounds:
   * We process your name, email address or Login ID, password, and Buyer Number
     for the purposes of enabling you to securely log in to your IAA account to
     make a payment, and allowing us to process your transaction and notify you
     of your purchase status. The legal grounds for processing this information
     for these purposes are: (1) IAA’s legitimate interest in protecting the
     security of payments made to your account; (2) IAA’s legitimate interest in
     communicating with you about your purchase status; and (3) The processing
     is necessary for the performance of a contract between IAA and you.
   * If you have a Licensed Business Buyer Account, with your authorization, IAA
     processes your banking information, including your bank name, bank account
     number, bank address, date bank account opened, average balance of bank
     account, non-sufficient funds history, and other information pertinent to
     IAA’s acceptance of checks from you, for the purpose of verifying that IAA
     can safely accept checks from you. The legal ground for processing this
     information for this purpose is your consent, which can be withdrawn by
     revoking the authorization permitting your bank to release such information
     to IAA.
   * If you choose to transport a vehicle using IAA Transport, we process your
     shipping address for the purpose of obtaining a quote for transportation
     services, scheduling transportation, and tracking shipment of your vehicle.
     The legal ground for processing this information for these purposes is
     IAA’s legitimate interest in providing customers with convenient and
     reliable vehicle transportation services.

Personal data that is processed when you donate, consign, or sell a vehicle:
When you donate, consign, or sell a vehicle, we may collect your name, business
name, mailing address, email address, phone number, designation as a licensed
dealer, other business license, vehicle owner, taxpayer identification number
(e.g., social security number or employer identification number), as well as
information concerning your vehicle (e.g., VIN number, mileage, value of your
vehicle, and vehicle zip code).

 * Purposes and Legal Grounds: IAA processes this information for the purpose of
   permitting you to donate, consign, or sell your vehicle. The legal grounds
   for processing this information is that it is necessary for the performance
   of a contract between IAA and you, and IAA’s legitimate interest in complying
   with applicable legal requirements. When you donate a vehicle, your personal
   data may also be shared with the benefactor charity for the purpose of
   allowing the benefactor charity to thank you for your donation. The legal
   ground for processing this information for this purpose is the benefactor
   charities’ legitimate interest in thanking donors.

Personal data that is processed when you request access to IAA industry reports,
submit a form to learn more about an IAA service, or register for our contests,
newsletters, clubs, activities, discussion lists, or announcement lists: When
you request access to IAA industry reports, submit a form to learn more about an
IAA service, or register for our contests, newsletters, clubs, activities,
discussion lists, or announcement lists, we may collect your name, company name,
email address, city, and state.

 * Purposes and Legal Grounds: IAA processes this information for the purpose of
   permitting you to access IAA industry reports, learn more about an IAA
   service, or register for our contests, newsletters, clubs, activities,
   discussion lists, or announcement lists. The legal ground for processing this
   information for these purposes is IAA’s legitimate interest in permitting you
   to have access to the information and services that you request.

Personal data that is processed when you complete a customer survey: When you
complete a customer survey we may collect your name, mailing address, email
address, phone number, company name, job title, emergency contact, and
information about your customer experiences, preferences, and interests.

 * Purposes and Legal Grounds: When you complete a customer survey, the
   information you choose to provide to us will be processed, analyzed, and used
   in reports and other analyses of consumer experiences and preferences for the
   purposes of improving and marketing IAA’s goods or services, or for any other
   uses we disclose to you at the time the information is collected. The legal
   ground for processing your personal data for these purposes is IAA’s
   legitimate interests in obtaining feedback from our customers in order to
   help us improve and market our products and services for the benefit of our
   customers and our business.

Personal data that is processed for marketing purposes: When you register for an
account, download the IAA buyer app, search for vehicles, place bids, purchase
products, request information, complete a customer survey, or otherwise provide
us with personal data, we may process your personal data for marketing purposes.
We may also collect personal data from third-party sources, including our
affiliates and organizations, such as the National Independent Automobile
Dealers Association (NIADA). With your consent, we may access your mobile device
location for the purpose of communicating with you when you are in close
proximity to one of our auction locations. The electronic marketing
communications you receive from IAA may be based on your location, and other
indicators, such as your bidding behavior and typical purchases (e.g., location,
vehicle type, mileage).

 * Purposes and Legal Grounds:
   * We process your email address, mobile device number, location (city, state,
     zip), buyer type (public vs. nonpublic), and other contact and demographic
     data to send you periodic marketing materials, including but not limited to
     birthday and anniversary cards, sponsored social media marketing messages,
     mobile notifications of our auctions, and other electronic marketing
     communications and publications for the purpose of notifying you of IAA’s
     products and services, product updates, special offers, and other issues.
     We may also share your personal data with our social media partners that
     assist us in identifying others who are likely to be interested in IAA’s
     products and services.
     * The general legal ground for processing your email address and other
       contact data for this purpose is IAA’s legitimate interest in providing
       our customers and our potential customers with marketing materials to
       effectively promote IAA’s products and services.
     * If you provide your consent to receive marketing communications and
       publications from IAA, the legal ground for processing your email address
       and other contact data for this purpose is your consent, which you may
       withdraw at any time by through the Unsubscribe link at the bottom of
       each electronic marketing communication or by updating your preferences
       in our Profile Center or Subscription Center. Buyers will also have the
       opportunity to opt-out of receiving push notifications through the IAA
       buyer app.
   * We process location and other information, such as bidding behavior,
     typical purchases, interests, and preferences for the purpose of providing
     our customers and potential customers with electronic marketing
     communications that are likely to be of specific interest to them. The
     legal ground for processing location data is your consent, which you may
     withdraw by adjusting your mobile device settings. The legal ground for
     processing information concerning bidding behavior, typical purchases,
     interests, and preferences is our legitimate interest in providing our
     customers and potential customers with electronic marketing communications
     that are likely to be of interest to them rather than sending every
     electronic marketing communication to every customer.

Personal data that is processed when you upload information or content to the
IAA website, including videos, comments, feedback, and other information: If you
upload videos, comments, feedback, or other information, we will collect any
personal information contained in such content. Please keep in mind that
whenever you voluntarily disclose personal data online in a forum accessible by
others, for example through email, a newsgroup, discussion lists, or elsewhere,
that personal data can be collected and used by others. If you post personal
data online that is accessible to the public, you may receive unsolicited
messages from other parties in return. Please exercise caution whenever you post
information online.

 * Purposes and Legal Grounds: IAA processes your videos, comments, feedback,
   and other information for the purpose of providing our users with the
   opportunity share such content with other users. The legal ground for
   processing this information for this purpose is IAA’s legitimate interest in
   enabling our users to provide comments, feedback, and other information they
   desire to share with IAA and other viewers of IAA’s Sites.

Personal data that is processed when you sign in to your IAA account using
social media: If you choose to sign in to your IAA account using your social
media sign-in credentials (e.g., your Facebook sign-in credentials), the first
time you do so you will be asked whether you agree that the social media
provider may provide certain information to IAA, such as your name, email
address, gender, age, likes, interests, profile photo, posts, comments and other
information associated with your social media account. All of this is made
available to IAA by the social media provider due to the way the social media
sign-on configuration works. If you do not want your information to be shared
with IAA by the social media provider, you can simply sign in to your IAA
account using your IAA account credentials instead of your social media
credentials.

 * Purposes and Legal Grounds: IAA processes this information to provide you
   with an alternative method to sign in to your IAA buyer Account, and for the
   purpose of creating effective marketing campaigns and customizing marketing
   that is focused on your preferences. The legal grounds for processing this
   information for these purposes is IAA’s legitimate interest in providing you
   an alternative sign-in method, and effectively marketing our products and
   services to our customers.

Personal data that is processed when you apply to be listed as a transportation
vendor, export vendor, or inbound tower: If you apply to be listed as a resource
for buyers in need of transportation and/or shipping services, or as a tower
looking for inbound towing opportunities, you will be asked to complete an
application, which may collect your name, company name, URL, mailing address,
phone number, email address, years in business, and information about your
services.

 * Purposes and Legal Grounds: IAA processes this information for the purpose of
   determining whether you are eligible to be listed as a resource for buyers
   looking for transportation/shipping services, or as a tower looking for
   inbound towing opportunities. The legal ground for processing this
   information for these purposes, is IAA’s legitimate interest in providing
   buyers with reliable transportation/shipping resources; identifying reliable
   vendors for inbound towing opportunities; and complying with applicable legal
   requirements.

Personal data that is processed when you upload your resume and/or apply for a
position at IAA: If you choose to upload a copy of your resume and/or complete
an application, we may collect a variety of personal data, including your name,
mailing address, email address, phone number, Social Security number, work
experience, education history, references, information about your applicable
degrees, licenses, and certifications, veteran status, whether you are 18 years
of age or older, whether you are legally eligible to work in the country to
which you are applying, whether you will require an employer to sponsor you for
employment-based visa status in the U.S., whether you have a valid driver’s
license, whether you or your relatives have ever worked for IAA or one of our
affiliates, your pay expectations, whether you are willing to relocate if
required and any other information in your application that you choose to share
with us, such as personal preferences, hobbies, social preferences, etc.

 * Purposes and Legal Grounds: IAA processes this information for the purpose of
   permitting you to be considered and evaluated for open positions that IAA is
   seeking to fill. The legal ground for processing this information for this
   purpose is IAA’s legitimate interest in analyzing resume and application
   information in connection with identifying qualified candidates to fill open
   positions at IAA, and compliance with IAA’s legal obligations where laws or
   contractual obligations require the processing of personal information.

Personal data that is processed when we use cookies and similar technologies to
collect Usage Data: IAA’s web servers collect personal data pertaining to users
of our Sites and the mobile devices and programs from which they access our
Sites (“Usage Data”). Usage data can include IP address, domain name, referring
web page, browser type, mobile device type and location, device operating
system, device settings, and information about the way you use your device or
the Sites (such as session time, pages visited, links or ads clicked, and
whether a user is new or returning). Mobile applications collect device
identifiers, and also may request permission to access certain features (e.g.,
microphone, camera, location) and display push notifications.

Usage data is gathered using the following methods: (1) cookies, (2) tags
(a.k.a. web beacons or clear gifs), (3) conversion tracking (track clicks to
sales from search results or ads), (4) general detection and use of your
internet protocol (IP) address or domain name, and (5) third-party website
analytics tools, including Google Analytics. IAA does not track individual
user’s online activities over time across third party websites (and thus does
not monitor your browser’s Do Not Track indicator).

Cookies

A cookie is a token that a server gives to your browser when you access an
Internet website. Cookies can store many types of data. Cookies can help provide
additional functionality to the Sites or help us analyze Site usage more
accurately. Information gathered from the use of cookies may be combined with
other data sources.

For more information on the types of cookies we collect, to control cookie
settings and/or to disallow, delete and otherwise manage cookies, please visit
our “Privacy Preference Center” with additional information about the different
types of cookies used (e.g., strictly necessary, performance, functional,
targeting) and your options for setting controls. You may also send an email to
Privacy@iaai.com. Additionally, if you reside in the European Union or other
jurisdiction that requires us to obtain your consent to use cookies on our
Sites, then you will have an opportunity to manage your cookie preferences on
our Sites, other than certain cookies required to enable core Site
functionality, which you cannot choose to disable.

 * Purposes and Legal Grounds: Usage data is collected for the purpose of
   helping us manage and administer our Sites, improving the content of our
   Sites, measuring the effectiveness of our advertising, Site administration
   and analytic purposes, providing aggregate or statistical reviews of user
   Site traffic patterns, personalizing content and internal ads, providing
   social media features, and customizing and improving the user experience and
   functionality of our Sites. The legal ground for processing this data for
   these purposes is our legitimate interest in conducting analytics and
   understanding how users interact with our Sites, so we can enhance the user
   experience and functionality of our Sites. If you do not want Usage Data
   collected through the use of these technologies, there is a simple procedure
   in most browsers that allows you to automatically decline many of these
   technologies, or to be given the choice of declining or accepting them.

THIRD-PARTY RECIPIENTS OF PERSONAL DATA

In connection with the purposes set forth in this Privacy Policy, we may share
your personal data with:

 * Our affiliates: Your personal data may be shared with any member or affiliate
   of our corporate group.
 * Other data subjects: Your personal data may be shared with other users of our
   Sites (e.g., when you upload videos, comments, feedback, and other
   information).
 * Select business partners and third-party service providers: Your personal
   data may be shared with our business partners, third-party service providers,
   contractors and sub-contractors, including:
   * Electronic payment vendors: We use electronic payment vendors to process
     credit card data and to utilize I-Pay, which enables qualified buyers with
     company check writing privileges to make payments directly from a
     U.S.-based bank account via the Internet.
   * Third-party advertising, social media, and analytics partners: We also
     share information about your use of the Sites with our social media,
     advertising and analytics partners. Our third-party ad networks and social
     media companies may use cookies, tags and other technology to collect
     information about your browsing activities over time and across different
     websites when you visit our Sites. Third party vendors or ad networks may
     use cookies, tags and other mechanisms to serve ads on other sites based on
     a user’s prior visits to our Sites. You may opt out of participation with
     various third-party networks by visiting the Network Advertising Initiative
     opt out page. We also share information about your use of our Sites with
     our third-party providers that assist us with improvement and optimization
     of our Sites.
   * Third-party app, platform or other service providers: We share the personal
     data we collect with third-party app, platform and other service providers,
     such as database managers/developers, and web developers/hosting companies
     that assist us with certain processing activities, such as storing/backing
     up data, enhancing/maintaining databases, publishing content, and
     developing/offering a variety of products/services. If you use our Sites,
     your personal data, including name, contact information and any stored
     biographical/firm information within IAA’s database, may be stored and
     processed through some of our third-party app vendors. We also use third
     party providers to distribute organizational emails.
   * Third-party transportation vendors: If a buyer chooses to transport a
     vehicle using IAA Transport services, IAA shares the buyer’s contact
     information, including shipping address with our third-party transportation
     vendors for the purpose of obtaining quotes, scheduling transportation, and
     tracking shipments.
   * Third-party Marketing Alliance Partners: If you register for and/or attend
     one of our seminars, we may share your personal data with our marketing
     alliance partners, so they can assist you with your purchase and arranging
     for transportation and shipping services.
   * Third-party charities: When you donate a vehicle, we may share your
     personal data with the benefactor charity for the purpose of allowing the
     benefactor charity to personally thank you for your donation.
 * Governmental entities and third parties in connection with legal obligations,
   remedies and claims: We may disclose personal data about you to governmental
   entities, such as regulatory agencies, law enforcement, and judicial
   authorities, as well as other third parties under any of the following
   conditions: (a) if we have your valid consent to do so; (b) to comply with a
   valid subpoena, legal order, court order, warrant, legal process, or other
   legal obligation; (c) to enforce or apply any of our terms and conditions,
   policies, or other agreements; (d) exchanging information with other
   companies and organizations for the purposes of fraud protection and credit
   risk reduction; or (e) as necessary to pursue available legal remedies or
   defend legal claims. We also may be required to disclose personal data in
   response to lawful requests by public authorities, including to meet national
   security or law enforcement requirements.
 * Third parties in connection with a potential reorganization: We may share
   your personal data to a prospective seller or buyer in the event of a
   potential reorganization, merger, sale, joint venture, assignment, transfer
   or other disposition of all or any portion of IAA’s assets or stock,
   including without limitation, in connection with any bankruptcy or similar
   proceeding, provided that such entity will not be permitted to process your
   personal data other than as described in this Privacy Policy without
   providing you notice and, if required by applicable laws, obtaining your
   consent.
 * Third parties in connection with screenings for jobs: We may also share your
   personal data with third parties who provide services to us such as
   recruitment agencies, consultants, background services and lawyers. If your
   personal information is shared in this way, IAA does so only on a
   “need-to-know” basis and will seek to ensure it is only used in connection
   with the functions or services these parties will be performing for IAA and
   that your personal information is treated by them in a confidential manner.
   These service providers that IAA uses may change over time but we will always
   seek to ensure that any third parties who handle your personal information
   will do so in a manner consistent with this Privacy Policy and in accordance
   with applicable law

Information We Collect from Other Sources

Financial institutions, manufacturing companies, and dealerships may also send
us information about you. We take measures to ensure that these third-parties
have a lawful or contractual right to collect, use, or disclose your information
before providing any data to us. This information is used for our legitimate
business interest.

LINKS TO OTHER SITES

As a resource to our visitors, our Sites contain offerings from other companies
that you can link to through our Sites (such as Automotive Finance Vendors,
Licensed Brokers, Transportation/Shipping Vendors, and Inspection Vendors). When
you click on such a link on our Sites, you will be taken to the website of the
other company, and its privacy practices will govern your use of that website
and your interactions with that company.

We try to carefully choose websites that we believe are useful and meet our
standards. However, the presence on our Sites of links to non-IAA websites does
not mean that IAA endorses or accepts any responsibility for the content or use
of such websites. IAA has no control over such websites, and has no
responsibility for the privacy practices of such websites.

CROSS-BORDER TRANSFERS OF PERSONAL DATA

We store our data on servers in the United States. If you are located outside
the U.S., your personal data will be transferred to servers in the U.S. The data
protection laws of the U.S. may not be as comprehensive as the laws of your
country. For example, personal data transferred to the U.S. may be subject to
lawful access requests by federal and state authorities in the U.S. IAA may
transfer your personal information to other countries such as India and the
Philippines for the purposes described in this Privacy Policy. In order to
provide adequate protection of your personal information, we have in place
contractual arrangements (where appropriate) which cover these transfers and we
will take all reasonable measures to safeguard your information whenever it is
transferred.

Any transfers of personal data from the European Union, the United Kingdom
and/or Switzerland to the United States are made pursuant to the EU-U.S. Privacy
Shield, the Swiss-U.S. Privacy Shield, or pursuant to European
Commission-approved Standard Contractual Clauses, which are available at the
following link.

IAA participates in and complies with the EU-U.S. Privacy Shield Framework and
the Swiss-U.S. Privacy Shield Framework (Privacy Shield) as set forth by the
U.S. Department of Commerce regarding the collection, use, and retention of
personal data transferred from the European Union, the United Kingdom and/or
Switzerland to the United States in reliance on Privacy Shield. IAA has
certified to the Department of Commerce that it adheres to the Privacy Shield
Principles and the Swiss-U.S. Privacy Shield Principles (collectively, the
“Privacy Shield Principles”). If there is any conflict between the terms in this
Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles
shall govern. You can learn more about the Privacy Shield program, and view our
certification here.

IAA is committed to subject to the Privacy Shield Principles all personal data
received from the European Union, the United Kingdom and/or Switzerland in
reliance on the Privacy Shield. IAA is subject to the oversight of the U.S.
Federal Trade Commission, which has jurisdiction over IAA’s compliance with the
Privacy Shield Principles. IAA will remain responsible for the processing of
personal data in a manner inconsistent with the Privacy Shield Principles by
third parties to which IAA has transferred personal data unless IAA proves it is
not in any way responsible for the event giving rise to the damage.

You may contact IAA anytime with your privacy questions or concerns:
Privacy@iaai.com.

CHILDREN AND MINORS’ PRIVACY

Our Sites are not directed to individuals under the age of 18. We do not
knowingly collect or use any personal data from users under 18 years of age. No
information should be submitted to our Sites by visitors under 18 years of age,
and visitors under 18 years old are not allowed to register for our contests,
newsletter, clubs or activities. You must be 18 years or older to purchase
products. If we learn that we have collected personal data from someone under
18, we will take steps to delete the information as soon as possible.

RETENTION OF PERSONAL DATA

The personal data that we collect from you is stored on our secure servers for
as long as is reasonably necessary for the purposes for which the personal data
is processed and to meet IAA’s legal obligations.

PROTECTING YOUR PERSONAL DATA

We are committed to protecting the information entrusted to us. We have
implemented technical and organizational measures designed to assist in
maintaining the security and confidentiality of personal data; safeguarding
against anticipated threats to the confidentiality, integrity, and availability
of personal data; and protecting your personal data against accidental or
unlawful destruction, loss, alteration, and unauthorized access or disclosure.

However, whenever personal data is processed, there is a risk that such data
could be lost, misused, modified, hacked, breached, and/or otherwise accessed by
an unauthorized third party. No system or online transmission of data is
completely secure. In addition to the technical and organizational measures that
IAA has in place to protect your personal data, you should use appropriate
security measures to protect your personal data. If you believe that your IAA
account or any information you provided to us is no longer secure, notify us
immediately at Privacy@iaai.com.

YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA

If you reside in the European Union, you have various rights under the General
Data Protection Regulation (GDPR) regarding the processing of your personal
data, including under certain circumstances, the right to request access to and
rectification or erasure of your personal data, data portability, restriction of
processing of your personal data, the right to lodge a complaint with a
supervisory authority, and the right to object to the processing of your
personal data on certain grounds, including:

 * The right to object when your personal data is processed based on the
   legitimate interests of IAA or a third party, including profiling related to
   such legitimate interests.
 * The right to object when your personal data is processed for direct marketing
   purposes, including profiling related to direct marketing.

If you live in the European Union, and you wish to exercise any of these rights,
you can make a request by writing to us at the following local address: Data
Privacy Manager, Two Westbrook Corporate Center, Westchester, IL 60154. You may
also send an email to Privacy@iaai.com or submit a Data Subject Request form. If
you do not live in the European Union but you believe you have rights under your
local laws, please contact IAA at Privacy@iaai.com.

If you reside outside of the European Union, you may have similar rights under
your local laws. If you reside in California, please see below.

If you reside in the European Union, the United Kingdom or Switzerland, you also
have the right, under the Privacy Shield, to access and to correct, amend or
delete your personal data where it is inaccurate or where it has been processed
in violation of the Privacy Shield Principles, except where the burden or
expense of providing access would be disproportionate to the risks to your
privacy or where the rights of other individuals would be violated.

If you reside in the European Union, the United Kingdom or Switzerland, your
rights under the Privacy Shield include the right to notice of the choices and
means that IAA offers you for limiting the use and disclosure of your personal
data. IAA provides you with the opportunity to choose how your personal data may
be used under certain circumstances. If your personal data is to be used for a
new purpose that is materially different from that for which your personal data
was originally collected or subsequently authorized, or if your personal data is
to be disclosed to a third-party controller, IAA will provide you with an
opportunity to choose whether to have your personal data so used or disclosed.
When sharing your personal data with third-party processors that IAA has
retained to perform services on its behalf and pursuant to its instructions, IAA
may disclose your personal data without offering an opportunity to opt out.

IAA also provides you with specific rights related to your sensitive personal
data. “Sensitive Data” under the EU-U.S. Privacy Shield Framework is defined as
personal data specifying medical or health conditions, racial or ethnic origin,
political opinions, religious or philosophical beliefs, trade union membership,
or information specifying the sex life of an individual. Under the Swiss-U.S.
Privacy Shield Framework, “Sensitive Data” means personal data specifying
medical or health conditions, personal sexuality, racial or ethnic origin,
political opinions, religious, ideological or trade union-related views or
activities, or information on social security measures or administrative or
criminal proceedings and sanctions, which are treated outside pending
proceedings. If your sensitive personal data is to be used for a new purpose
that is different from that for which your sensitive personal data was
originally collected or subsequently authorized, or is to be disclosed to a
third party, IAA will obtain your affirmative express consent prior to such use
or such disclosure.

In compliance with the Privacy Shield Principles, IAA is committed to resolving
complaints about our collection and use of EU/UK/Swiss personal data. EU, UK
and/or Swiss individuals with inquiries or complaints regarding our Privacy
Shield policy should first contact IAA by email at Privacy@iaai.com or by
writing to us via mail at: Data Privacy Manager, Two Westbrook Corporate Center,
Westchester, IL 60154.

IAA has further committed to refer unresolved Privacy Shield complaints to JAMS,
an alternative dispute resolution provider located in the United States. If you
do not receive timely acknowledgement of your complaint from us, or if we have
not resolved your complaint to your satisfaction, please contact or visit
JAMSfor more information or to file a complaint. The services of JAMS are
provided at no cost to you. Additionally, you may, under certain conditions,
invoke binding arbitration for complaints regarding Privacy Shield compliance
that are not resolved by any of the other Privacy Shield resolution mechanisms.
More information about Privacy Shield arbitration is available here.

If your complaint involves human resources data transferred to the United States
from the EU and or United Kingdom in the context of an employment relationship,
and IAA does not address it satisfactorily, IAA commits to cooperate with the
panel established by the EU data protection authorities (DPA Panel), as
applicable and to comply with the advice given by the DPA panel, as applicable
with regard to such human resources data. To pursue an unresolved human
resources complaint, you should contact the state or national data protection or
labor authority in the appropriate jurisdiction. Complaints related to human
resources data should not be addressed to JAMS.

Contact details for the EU data protection authorities can be found at
https://edpb.europa.eu/about-edpb/board/members_en.

If your Privacy Shield complaint cannot be resolved through the above channels,
under certain conditions, you may invoke binding arbitration for some residual
claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at
https://www.privacyshield.gov/article?id=ANNEX-I-introduction.

ENTITIES COVERED BY THIS PRIVACY POLICY

Our following U.S. companies adhere to the Privacy Shield Principles:

 * IAA, Inc.
 * Auto Disposal Systems Inc
 * Automotive Recovery Services, Inc.
 * Decision Dynamics LLC
 * Impact Texas LLC
 * Insurance Auto Auctions Corp.
 * Insurance Auto Auctions of Georgia LLC
 * Insurance Auto Auctions
 * Insurance Auto Auctions Tennessee LLC

 

YOUR CALIFORNIA PRIVACY DISCLOSURES

This “Your California Privacy Disclosures” supplements the Privacy Policy and
contains the disclosures required under the California Consumer Privacy Act
(“CCPA”). For individuals who are California residents, the CCPA requires
certain disclosures about the categories of personal data we collect and how we
use it, the categories of sources from whom we collect personal data, and the
third parties with whom we share it.

Please note that for California residents, the term personal data as used in
this section (referred to as personal information under the CCPA) means
information that identifies, relates to, describes, is reasonably capable of
being associated with or could reasonably be linked, directly or indirectly,
with a particular consumer or household as defined in the CCPA. All other
capitalized terms have the same meanings as given them in the Privacy Policy.

If you are a California resident who has provided personal data to IAA, or a
California resident that reasonably believes that IAA collected or stores their
personal data, you may exercise your rights under the CCPA and submit your
requests in one of the following methods: (a) by submitting this online form;
(b) by calling the following toll free number 877-806-4827.

You have the right to request IAA to:

 1. (a) Disclose if we have collected personal data on you;
 2. (b) Disclose the categories of personal data that we have collected on you
    (if any); the categories of sources from which the personal data is
    collected; the business or commercial purpose for collecting or selling
    personal data; and the categories of third parties with whom the business
    shares personal data;
 3. (c) Disclose the specific pieces of personal data that we have collected on
    you (if any); and
 4. (d) Delete personal data we have collected on you (if you satisfy the
    conditions set out in the CCPA).

NOTE: we do not sell your personal data as that term is defined in the CCPA and
for this reason we do not provide an opt-out from the sale of your personal
data.

In order to submit a request, we will need to verify your identity. If you have
an account with us that is password-protected, we may verify your identity
through our existing authentication practices for your account.

If you do not have an account with us, and your request concerns “categories” of
personal data collected, we can request from you two data points of personal
data to verify your identity. If you do not have an account with us, and your
request concerns specific personal data, we can request from you at least three
data points of personal data as well as a signed declaration with penalty of
perjury to verify your identity.

Please note that following your verified request, we will send you your personal
data from the following email address: Privacy@iaai.com (Any response to your
request, including any personal data may be sent as an encrypted file).

Please note that once you have submitted a request, we will send you a receipt,
acknowledging your request, within 10 days. If, for some reason, you do not
receive such a receipt within 10 days of your submitted request, please send us
an email to Privacy@iaai.com as an error may have occurred.

We will process and respond to your request within 45 days after it is received
(in some cases, as is allowed under the CCPA, this process may be extended by an
additional 45-90 days). Please note, that regarding requests to know or access
under subsections (a), (b), and (c) above, you may only make two requests in a
12-month period, and the information provided need only cover the 12-month
period prior to your request.

Authorized Agent: As a California resident, you also have the right to designate
an agent to exercise these rights on your behalf. If you choose to exercise your
rights through the use of an authorized agent, we require that you verify the
agent’s identity, and provide written permission granting the agent authority to
submit a request on your behalf.

We hereby inform you that if you exercise any of your rights under the CCPA we
may not deny you goods or services for that reason, or subject you to different
prices than those paid by other consumers, unless provided otherwise under the
CCPA, Federal, or State law.

Notice of Information We Collect

Pursuant to California Civil Section 1798.100(b), this serves as notice of the
categories of personal data that we collect through the Site and Services and
the commercial purposes for which the information was collected. Please note
that all of the categories of personal data we collect about you (as detailed
below) come from the following categories of sources:

 * You, including through your use of our services
 * Automatically collected from you
 * Our affiliate companies
 * Third parties

In particular, we have collected the following categories of personal data from
California consumers within the last twelve (12) months:

Category Collected Purpose Identifiers. YES See CATEGORIES OF PERSONAL DATA
PROCESSED BY IAA above. Personal information categories listed in the California
Customer Records statute (Cal. Civ. Code § 1798.80(e)). YES See CATEGORIES OF
PERSONAL DATA PROCESSED BY IAA above. Protected classification characteristics
under California or federal law. NO Commercial information. YES See CATEGORIES
OF PERSONAL DATA PROCESSED BY IAA above. Biometric information. NO Internet or
other similar network activity. YES See CATEGORIES OF PERSONAL DATA PROCESSED BY
IAA above. Geolocation data. YES See CATEGORIES OF PERSONAL DATA PROCESSED BY
IAA above. Sensory data. YES See CATEGORIES OF PERSONAL DATA PROCESSED BY IAA
above. Professional or employment-related information. YES See CATEGORIES OF
PERSONAL DATA PROCESSED BY IAA above. Non-public education information (per the
Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R.
Part 99)). NO Inferences drawn from other personal data. NO

Notice of Disclosures of Personal Data for a Business Purpose

In the preceding 12 months, we disclosed certain personal data from the
following categories of personal information to the categories of recipients
listed in the Section entitled THIRD-PARTY RECIPIENTS OF PERSONAL DATA of our
Privacy Policy, such as our service providers, for one or more business purposes
as described in that Section: the categories A through K above.

We disclose the above categories of personal data to service providers to
fulfill the business purposes, such as:

 * Maintaining and servicing your account;
 * Providing you customer service;
 * Processing transactions;
 * Processing applications and payments;
 * Verifying the identity of users;
 * Detecting and preventing fraud;
 * Providing loyalty and promotional programs;
 * Providing marketing and advertising services;
 * Providing analytics services; and
 * Undertaking internal research to develop our services.

Please note that when we disclose personal data for a business purpose to a
third party, we enter a contract that describes the purpose and requires the
recipient to both keep that personal data confidential and not use it for any
purpose except performing the contract.

Do Not Track

IAA does not track its customers over time and across third-party websites and
online services (e.g., mobile apps), and therefore does not respond to Do Not
Track signals. However, some third-party sites and apps track your browsing
activities when they provide you content, which enables them to tailor what they
present to you. Third parties may collect personal data relating to your online
activities over time and across different sites and apps when you use our Sites.

Third-Party Marketing

If you are a California resident, California Civil Code Section 1789.83 permits
you to request (once per calendar year) information regarding the disclosure of
your personal data (if any) to third parties for the third parties’ direct
marketing purposes. If applicable, this information would include a list of the
categories of personal data shared and the names and addresses of any third
parties with whom such personal data was shared in the immediately preceding
calendar year. To make such a request pursuant to Shine the Light, contact us
via email at Privacy@iaai.com or by telephone at 877-806-4827.

 

DATA CONTROLLER

Personal Data collected by IAA is controlled by IAA, which is located at Two
Westbrook Corporate Center, Westchester, IL 60154 and which you can contact by
email at Privacy@iaai.com.

CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time as we add new products,
services, and apps; as we improve our current offerings and technologies; and as
laws change. It is our policy to post any changes we make to our Privacy Policy
on the Sites. Any changes will become effective upon our posting of the revised
Privacy Policy on the Sites. If we make material changes to how we treat the
personal data that falls within the scope of this Privacy Policy, we will notify
you by email (to the email address specified in your account) or through a
notice on the Sites. The date this Privacy Policy became effective is identified
at the top of the first page.

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