We are committed to protecting your privacy. This Privacy Policy is intended to help you understand what kind of
information we collect and how we use it.
We offer a variety of products that touch the lives of automotive enthusiasts just like you. Information gathered
while interacting with us through our products and services are all covered under this Policy. Products and services
include:
- Our websites, portals, and point of sale services
- Our customer care and warranty services
- Our customer events, promotions, and campaigns
- Our hard parts, electronics, and soft goods
- Our software and digital products
Your consent to the processing of personal data will be obtained by an appropriate mechanism such as ticking a box,
accepting a pop-up, enabling a setting for a service or website, or other statement or conduct clearly indicating
your acceptance to the processing. By consenting, you acknowledge and agree to the use of your data in accordance
with this Policy.
We may provide additional privacy related terms in connection with a particular COBB Tuning product or service. Such
terms prevail over this Policy to the extent of any conflict. Our products or services may contain links to other
companies’ websites and other third party services that have privacy policies of their own. We recommend that you
carefully read the privacy policies of such services as they are not covered by this Policy.
DATA COLLECTED
We collect your personal data when you purchase our products or services, use or register our products or services,
enter into a sales promotion or a campaign, or otherwise interact with us. Below are examples of the categories of
the personal data we may collect.
Browsing Information. For the most part, you may visit our websites or use our products or services
without having to identify yourself. However, certain technical information is normally collected as a standard part
of your use of our services. Such information includes, for example, your IP-address, access times, the website you
linked from, pages you visit, the links you use, the ad banners and other content you viewed, information about your
devices and other such technical information your browser provides us with or as may be otherwise collected in
connection with certain products and services. When you use our services or otherwise interact with us over
telecommunications networks, certain additional information, such as your mobile subscription number, may be
transmitted to us by the telecommunications operator as a standard part of that communication. Please also see the
section “Use of Cookies and Web Beacons” below.
Technical Information. Some of our software products and services collect information pertaining to
your use of the software, your computer hardware, your operating system, and use of connected COBB Tuning products.
An example scenario of a connected COBB Tuning product is when you use the Accessport Manager software to connect to
your Accessport device. The Accessport may provide details about the device itself (firmware, part number, etc) and
its usage (installation state, installed vehicle, log preferences, etc). In some cases, such as crash reports,
additional information about the state of the software (callstack, limited memory snapshots) during the crash will
be provided.
Information you provide us. When you register to our services, make a purchase, enter a sales
promotion or otherwise interact with us, we may ask you to provide us with certain information such as your name,
email address, street address, as well as user names, passwords and other such credentials that are used to
authenticate users and to validate their actions or that may be needed to provide you with the products and services
you have requested or to communicate with you, as well as information uploaded by you such as location, route
information, pictures etc. We may collect training data, demographic information, for example, your age, gender,
postal code and language preferences.
We may also collect other information you provide, such as your consents, preferences and feedback, information
relating to your devices and other such information you provide us with. Please note that certain non-identifiable
information collected from you may become personally identifiable when you provide us with your personal data.
Your transactions with us. We collect or request information relating to your purchase or use of our
products or services as well as your other interactions with us. Such information may include, for example, details
of the queries or requests you have made, the products and services provided (including delivery details),
purchasing details (including payments made, credit card details, billing address, credit checks and other such
financial information), details of agreements between you and COBB Tuning, records of contacts and communications,
information and details relating to the content you have provided us with and other such transactional information.
We may, in accordance with applicable law, record your communication with our customer care or with other similar
contact points.
Location data. Certain services may involve the use of your location data. Use of your location data
is, however, subject to your prior consent for each service.
THE PURPOSES OF PROCESSING
We use your personal data to provide quality products and services. Such use may be necessary for minimum level of
service, such as buying a product online. Additional examples can be found below, described elsewhere in this
Policy, and/or any provided additional service specific privacy information. Please note that one or more purposes
may apply simultaneously.
Provision of products and services. We use your personal data to provide you the product or service
you have requested, fulfill other requests such as customer service, process your order or as otherwise necessary to
perform or enforce the contract between you and us. We may also use your personal data to ensure the functionality
and security of our products and services, to identify you, and to prevent and detect fraud and other misuses.
Development of products and services. We may use your personal data to develop our products and
services. Whenever possible, information used for this purpose is stored anonymously or pseudonomously. Any personal
data processed and aggregated for statistical analysis, is not directly identifiable to you.
Communicating with you and marketing. We may process and use your personal data to communicate with
you, for example, to provide information relating to our products and/or services you are using or to contact you
for customer satisfaction queries. We may process and use your personal data for marketing. Marketing purposes may
include using your personal data for personalized marketing or research purposes in accordance with applicable laws,
for example, to conduct market research and to communicate our products, services or promotions to you via our own
or third parties’ electronic or other services.
In addition, some of our products and services may be used to promote products and services of other companies.
However, we will not disclose your personal data to such companies for their marketing purposes without your prior
consent.
Profiling/personalization. We may process and use your personal data for profiling/personalization
for such purposes as targeted direct marketing, to provide you with service more relevant to you and improvement of
our products or services.. Profiling/personalization includes automated processing of your personal data for
evaluating, analyzing or predicting your personal preferences or interests in order to, for example, send you
marketing messages concerning products or services best suitable for you. We may combine personal data collected in
connection with your use of a particular COBB Tuning product or service with other personal data we may hold about
you, except where such personal data was collected for a different purpose.
TRANSFERS OF YOUR PERSONAL DATA
From time to time we may disclose your personal data to third parties solely for purposes stated in this Policy. Such
parties are not permitted to use your personal data for any other purposes than for what your personal data was
collected, and we require them to act consistently with applicable laws and this Policy as well as to use
appropriate security measures to protect your personal data. Your personal data will not be sold to third parties.
Opting-out from e-mail/SMS based marketing. You may opt-out from brand marketing e-mails by
following the guidance in those e-mails (typically provided via “unsubscribe” link) or by contacting us as set forth
in the e-mail and on our web site. If you opt-out, we may still send you non-marketing e-mails, such as service
notifications or other information or if you are a business customer, we may send business relation information. You
may also opt-out from any SMS based direct marketing by contacting us as set forth our on site or via SMS as may be
applicable.
Service providers and other authorized third parties. We may transfer your personal data to
authorized third parties who process personal data on behalf of COBB Tuning Products LLC for the purposes described
in this Policy, such as e.g., technical, logistics, e-commerce, marketing and other service providers.
International transfers. Our products and services may be provided using resources and servers
located in various countries around the world. Therefore your personal data may be transferred outside the country
where you use our services, including to countries outside the European Economic Area (EEA), where the level of data
protection may not be deemed adequate by the European Commission. In such cases we take steps to ensure that
adequate protection for your personal data is provided as required by applicable laws. For international transfers
of your personal data, we generally rely on agreements that are based on the Standard Contractual Clauses (“SCCs”)
of the European Commission. You may find the SCCshere. If you wish to know more about international
transfers of your personal data, you may contact us via the contact details given below.
Other disclosures. We may disclose and otherwise process your personal data in accordance with
applicable laws to defend our legitimate interests, for example, in civil or criminal legal proceedings.
Mergers and Acquisitions. If we decide to sell, buy, merge or otherwise reorganize our businesses in
certain countries, this may involve us disclosing personal data to prospective or actual purchasers and their
advisers, or receiving personal data from sellers and their advisers, strictly for the purposes of such
transactions.
DATA CONCERNING MINORS
We do not seek to collect any information from or engage in any transactions with persons under the legal age in
their respective country. Our databases may nevertheless contain personal data of minors where it is not possible to
determine the age of the user. We reserve the right to block the service from any person who is or whom we
reasonably suspect of being a minor.
We request that minors do not make purchases or engage in other legal acts on our products and services without the
consent of a parent or legal guardian, unless otherwise permitted by applicable law. If you are a minor but have
your legal guardian’s consent, you must be able to prove that such consent exists upon request.
DATA QUALITY AND RETENTION
We take reasonable steps to keep the personal data we possess accurate and up-to-date and to delete out of date or
otherwise incorrect or unnecessary personal data.
Certain products and services may allow you to manage your profile and the information in such profile. We encourage
you to access your personal data via your profile from time to time to ensure that it is correct and up-to-date.
Please remember that for such electronic services where you may manage your profile, it is your responsibility to
provide us with correct details as well as to update the personal data you have provided us with in case of any
changes.
We store your personal data only for a period necessary for the purpose in question or as long as required by
applicable laws.
DATA SECURITY
We use appropriate technical and organizational security measures to prevent and minimize risks associated with
providing and processing personal data.
Such security measures include, where appropriate, the use of firewalls, secure server facilities, encryption, access
rights management systems and processes, the separation of data from direct identifiers so that linkage to an
identity is not possible without additional information that is held separately, careful selection and limitation of
processors, sufficient training of those involved in the processing, and other necessary measures to protect your
personal data against unauthorized use or disclosure. Where appropriate, we may also take back-up copies and use
other such means to prevent accidental damage or destruction of your personal data. Industry standard security
measures, such as the one available through “Secure Sockets Layer” (“SSL”), are used to protect the confidentiality
and security of online transactions.
USE OF COOKIES AND WEB BEACONS
When you visit our websites, information may be placed on your computer or device by your web browser. This
information allows us to provide a quality browsing experience. Our use of this information provides benefits to
you, such as recognizing your computer, recalling your preferences, eliminating the need for you to enter your
password frequently, and remembering items you’ve placed in a shopping cart. The technologies below may also be used
for website traffic analysis and profiling to improve our services. However, we do not use them to identify
individual users personally.
You acknowledge and agree to the storage of cookies, other local storage technologies, beacons and other information
on your devices and to the access of such cookies, local storage technologies, beacons and information by us and by
the third parties mentioned above.
“Cookies”, in the form of text files, are a way web browsing information is stored on your computer. If you wish to
disable cookies, or want to be notified before they are placed, you may do this in your browser settings. For
example, if you are using Internet Explorer, you may disable and manage cookies by following the instructionshere.
Further information about controlling of cookies can be found here.We may not be able to provide certain services,
or you may not be able to view certain parts of this site, if you have disabled cookies.
Other kinds of local storage technologies, such as Local Shared Objects (also referred to as “Flash cookies”) and
HTML5 local storage may also be used. These technologies make use of different parts of your device from standard
cookies, and you might not be able to control them using standard browser tools and settings. For example, you can
prevent Flash cookies from being stored by following the instructions provided by Adobe here.
Web beacons (or “pixel tags”) may also be used when browsing. These are typically graphic images that are placed on a
website to count visitors and/or to access certain cookies. Web beacons do not typically collect any other
information than what your browser provides as a standard part of any internet communication. If you turn off
cookies, the web beacon will no longer be able to track your specific activity. The web beacon may, however,
continue to collect information of visits from your IP-address, but such information will no longer be personally
identifiable.
Some of our business partners whose content is linked to or from our website may also use cookies or web beacons.
However, we have no access to or control over these cookies.
YOUR RIGHTS
You have the right to request and access the personal data we have collected from and of you. You also have the right
to request that we replenish, rectify, anonymize or delete any incomplete, incorrect, unnecessary or outdated
personal data we hold on you. However, we cannot delete such personal data that is necessary for compliance with
binding legal obligations or if the personal data must be retained according to applicable laws. The personal data
we have collected on you will be delivered in a commonly used and machine-readable form. In case you do not wish
your personal data to be deleted where the processing of your personal data has been deemed unlawful or the personal
data is no longer necessary, or you have objected to the processing and the existence of legitimate grounds for
processing is still under consideration, you may request restriction of processing of your personal data.
You may also at any time object to your personal data being processed for direct marketing purposes, sending
promotional materials, profiling, or for the performance of market research. Further, where your personal data is
processed based on your consent, you have the right to withdraw your consent for such processing at any time.
In case you wish to make use of your rights mentioned above, you may, as appropriate and in accordance with
applicable laws, exercise such rights by contacting us through the contact points referred in the marketing
materials or below in this Policy. In some cases, especially if you wish us to delete or cease the processing of
your personal data, this may also mean that we may not be able to continue to provide the services to you. We
encourage you to use available profile management tools for the above purposes as such tools often provide you with
direct access to your personal data and allow you to effectively manage it.
Please note that we may need to identify you and to ask for additional information in order to be able to fulfill
your above requests. Please also note that applicable law may contain restrictions and other provisions that relate
to your above rights.