Lectrium Privacy Policy
Lectrium, Inc. (“Lectrium,” “we,” “us,” or “our”) is committed to protecting your privacy. This Privacy Policy outlines how we collect, use, share, and safeguard your personal information when you use our digital tools embedded on dealership websites and when you use the Lectrium Dealer Portal at app.lectrium.com. By accessing or using our services, you agree to the terms of this Privacy Policy.
This Privacy Policy works together with our Terms & Conditions, which govern your access to and use of Lectrium’s tools and services.
1. Key Terms
1.1. Personal Information: Information that identifies, relates to, or could reasonably be linked to a particular individual or household. 1.2. Nonpublic Personal Information (NPI): Personally identifiable financial information that is not publicly available. 1.3. Affiliates: Entities that control, are controlled by, or are under common control with Lectrium. 1.4. OEMs: Original Equipment Manufacturers, such as vehicle manufacturers. 1.5. Embedded Tools: The Lectrium tools that appear on dealership websites and are used by vehicle shoppers, including the EV Savings Badge, the EV Range Map, the CO₂ Savings Badge, and the AI Chat Assistant. 1.6. Dealer Portal: The Lectrium application at app.lectrium.com, used by dealership staff and Lectrium personnel to administer dealership accounts, review leads, and view analytics. 1.7. Google User Data: The information that Google provides to Lectrium when you choose to sign in to the Dealer Portal with your Google account.
2. Information We Collect
2.1. From vehicle shoppers who use the Embedded Tools, we collect the following types of personal information: 2.1.1. Contact Information: Names, email addresses, phone numbers, and, in some cases, home addresses. Note that some tools may require you to provide certain information according to the IRS Publication 5899 (Clean Vehicle Credit Transfer: Information you need to provide to the registered dealer) and Publication 5900 (Important Information for Consumers Transferring Clean Vehicle Tax Credits). 2.1.2. Vehicle Interest Information: Details about vehicle preferences and potential eligibility for federal or state incentives. 2.1.3. Usage Data: Information on how you interact with our tools, such as pages visited and features used. 2.1.4. Conversation Data: The content of your interactions with the AI Chat Assistant, including the questions and messages you submit and the responses generated. You should not enter sensitive personal or financial information into the chat; contact details for follow-up are collected only through the lead form. 2.2. From Dealer Portal users, we collect the following types of personal information: 2.2.1. Account Information: Your name, your work email address, the dealership or organization you belong to, and your assigned role and permissions. 2.2.2. Authentication Information: Credentials used to verify your identity, including a hashed password if you set one, session identifiers, and, where you sign in with Google, the Google User Data described in Section 5. 2.2.3. Portal Usage Data: Records of your activity inside the Dealer Portal, such as pages viewed, records accessed, and configuration changes you make. We use these records for security, auditing, and support.
3. How We Collect Information
3.1. We collect personal information directly from vehicle shoppers who voluntarily complete lead forms or contact requests on dealership websites utilizing Lectrium’s Embedded Tools. We also collect Conversation Data when you interact with the AI Chat Assistant, including any information you choose to include in your messages. 3.2. We collect personal information from Dealer Portal users when an account is created for them, when they set a password, when they sign in, and as they use the Dealer Portal. Where a user chooses to sign in with Google, we receive the Google User Data described in Section 5 directly from Google.
4. Use of Information
4.1. We use the collected personal information to: 4.1.1. Facilitate communication between you and dealerships, OEMs, or their representatives. 4.1.2. Provide, maintain, and improve our services. 4.1.3. Respond to your inquiries or requests. 4.1.4. Comply with applicable laws and regulations. 4.1.5. Analyze aggregated, anonymized data for insights and product enhancement. 4.1.6. Operate and provide the AI Chat Assistant, including processing Conversation Data through third-party artificial intelligence service providers that act on our behalf. 4.1.7. Use de-identified or aggregated Conversation Data to analyze, maintain, and improve our tools and services. 4.1.8. Create and administer Dealer Portal accounts, authenticate users, secure sessions, apply role-based access controls, and provide customer support.
5. Dealer Portal Accounts and Google Sign-In
5.1. Lectrium operates the Dealer Portal at app.lectrium.com for dealership staff and Lectrium personnel. Access is granted by invitation. The Dealer Portal is not a consumer service, and vehicle shoppers do not hold Dealer Portal accounts. 5.2. What Google provides. If you choose to sign in with Google, Google provides Lectrium with your Google account email address, your basic profile information (your name and your profile picture), and a stable identifier for your Google account. Lectrium requests only the email and profile scopes. Lectrium does not request, receive, or access your Gmail messages, your Google Drive files, your Google Calendar, your contacts, or any other Google service. 5.3. How we use it. Lectrium uses Google User Data only to: 5.3.1. Match you to an existing Dealer Portal invitation or account. 5.3.2. Create your Dealer Portal account and establish your identity within it. 5.3.3. Authenticate you and maintain your signed-in session. 5.3.4. Display your name and profile picture to you and to other authorized users of your dealership’s workspace. 5.4. How we store it. Google User Data is stored in Lectrium’s authentication system, hosted on servers located in the United States, and protected by the measures described in Section 9. Lectrium does not receive or store your Google password. 5.5. How we share it. Lectrium does not sell Google User Data. Lectrium does not transfer Google User Data to advertisers, data brokers, OEMs, or any other third party for their own purposes. Lectrium does not use Google User Data to train, develop, or improve any artificial intelligence or machine learning model, whether our own or a third party’s. Google User Data is disclosed only to service providers that host or operate the Dealer Portal on Lectrium’s behalf and under contract, and only where a law or a valid legal process requires disclosure. 5.6. How long we keep it. Lectrium retains Google User Data for as long as your Dealer Portal account remains active, and thereafter only as necessary to comply with legal obligations, resolve disputes, and enforce our agreements. 5.7. How to remove it. You may revoke Lectrium’s access to your Google account at any time from your Google Account permissions page at https://myaccount.google.com/permissions. You may request that Lectrium disconnect your Google account from the Dealer Portal, or that Lectrium delete your Dealer Portal account and its associated data, by writing to info@lectrium.com. 5.8. Lectrium’s use of information received from Google APIs adheres to the Google API Services User Data Policy (https://developers.google.com/terms/api-services-user-data-policy), including the Limited Use requirements.
6. Data Sharing
6.1. Personal information collected by Lectrium through the Embedded Tools is shared with dealerships, OEMs, or certification program managers based on established agreements. We also share information with service providers who process it on our behalf and under contract, solely to provide and support our services, including third-party artificial intelligence service providers that process Conversation Data to operate the AI Chat Assistant. These service providers are not permitted to use the information for their own purposes. Sharing information with a service provider that processes it on our behalf is not a “sale” of personal information. We do not sell personal information. 6.2. AI Chat Assistant Processing. Conversation Data is processed by third-party artificial intelligence service providers acting as service providers (subprocessors) on Lectrium’s behalf, solely to generate responses within the AI Chat Assistant. The AI service providers we use do not use Conversation Data to train or improve their own models. If a dealership selects an AI model or provider whose terms differ, that provider’s terms will govern the processing of conversation content. 6.3. Dealer Portal Data. Account Information, Authentication Information, and Portal Usage Data are not shared with OEMs, advertisers, or data brokers. They are disclosed only to service providers that host or operate the Dealer Portal on Lectrium’s behalf and under contract, to the dealership or organization that the account belongs to, and where a law or a valid legal process requires disclosure.
7. User Consent (TCPA & CCPA Compliance)
7.1. By submitting your personal information through our Embedded Tools, you explicitly consent to the following: 7.1.1. “By providing my contact information and clicking submit, I authorize the dealership, its representatives, or affiliated OEMs to contact me via phone, email, or SMS (including autodialed calls and robotexts) regarding the vehicle or related dealership services. I confirm that I am the current owner/subscriber of the provided contact information or have explicit permission from the subscriber to share it. Consent is not required for purchase, and I may opt-out anytime by emailing info@lectrium.com.” 7.1.2. “By providing my personal information and clicking submit, I acknowledge that I have read and agree to the Privacy Policy. I consent to the collection, use, and disclosure of my personal information as described therein, including practices regarding data collection, usage, and sharing. I understand that I have the right to access, delete, or opt out of the sale of my personal information as outlined in the California Consumer Privacy Act (CCPA). To exercise these rights or for more information, I may contact info@lectrium.com.”
8. California Consumer Privacy Act (CCPA) Rights
8.1. If you are a California resident, you have specific rights regarding your personal information under the CCPA. These rights apply both to information collected through the Embedded Tools and to information collected through the Dealer Portal: 8.1.1. Right to Know: You can request that we disclose the categories and specific pieces of personal information we have collected about you, the sources of that information, our purposes for collecting it, and the categories of third parties with whom we share it. 8.1.2. Right to Delete: You can request that we delete any personal information we have collected from you, subject to certain exceptions. 8.1.3. Right to Opt-Out: You can opt-out of the sale of your personal information. However, Lectrium does not sell personal information. 8.1.4. Right to Non-Discrimination: You have the right not to be discriminated against for exercising your CCPA rights. 8.2. To exercise these rights, please contact us at info@lectrium.com. We will respond to your request within 30 days.
9. Data Security Measures
9.1. We maintain physical, technical, organizational, and administrative security measures designed to protect your personal information from unauthorized access, use, alteration, or destruction. 9.2. We retain personal information and Conversation Data for as long as necessary to provide our services, which generally means for the duration of Lectrium’s contractual relationship with the relevant dealership, and thereafter only as necessary to comply with legal obligations, resolve disputes, and enforce our agreements. Dealer Portal account data is retained as described in Section 5.6.
10. International Data Transfers
10.1. All servers hosting personal information are located in the United States. If you access our services from outside the U.S., please be aware that your information will be transferred to, stored, and processed in the U.S.
11. Updates to the Privacy Policy
11.1. We reserve the right to change this Privacy Policy at any time by posting a new version on our website. Your continued use of the service after any changes are posted will be deemed to constitute your agreement to and acceptance of such changes.
12. Contact Information
12.1. For any questions regarding this Privacy Policy or your personal data, please contact us at: Lectrium, Inc. 3175 Hanover Street Palo Alto, California 94304 United States Email: info@lectrium.com
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