Privacy Notice
Commercial Vehicle Group, Inc. and its affiliates (“CVG and/or Aftermarket Truck Parts,” “we,” “our,” and/or “us”) value the privacy of individuals who use our websites and related services (collectively, our “Services”). This Privacy Notice explains how we collect, use, and disclose the information of users of our Services (“Users” or “you”). By using our Services, you agree to the collection, use, disclosure, and processing of your information as described by this Privacy Notice.
If you are a resident of California, Colorado, Connecticut, Utah, and Virginia, you can view our Detailed US Privacy Notice at Please see attached.
- Information We Collect
We may collect a variety of information about you or your devices from various sources, as described below.
- Information You Provide to Us
Registration Information. If you sign up for an account, register to use our Services, or sign up for emails or other updates, we may ask you for basic contact information, such as name, email, username, phone number, or mailing address.
Communications. If you contact us directly, we may collect additional information from you. For example, when you reach out to our customer support team, we may ask for your name, email address, mailing address, phone number, or other contact information so that we can verify your identity and communicate with you. We may also store the contents of any message or attachments that you send to us, as well as any information you submit through any of our forms or questionnaires.
Payment Information. If you make a purchase through the Services, your payment-related information, such as credit card or other financial information, may be collected by our third-party payment processor on our behalf.
- Information We Collect Automatically When You Use Our Services.
Device Information. We may collect information about the devices and software you use to access our Services, such as your IP address, web browser type, operating system version, device identifiers, and similar information.
Usage Information. To help us understand how you use our Services and to help us improve them, we may collect data about your interactions with our Services. This includes information such as crash reports, session lengths and times, the pages or other content you view, and any searches you conduct.
Cookies and Similar Technologies. We and our third-party partners may collect information using cookies, pixel tags, or similar technologies. Cookies are small text files containing a string of alphanumeric characters. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to our Services.
Please note that we or other parties may collect personal information about your online activities over time and across different devices and online properties when you use the Services. Your web browser may have settings that allow you to transmit a “Do Not Track” signal when you visit various websites or use online services. Like many websites, our Services are not designed to respond to “Do Not Track” signals received from browsers. To learn more about “Do Not Track” signals, visit allaboutdnt.com.
- How We Use the Information We Collect
We may use the information we collect:
- To provide, maintain, improve, and enhance our Services;
- To understand and analyze how you use our Services and develop new products, services, features, and functionality;
- To facilitate purchases of products or services that you order;
- To communicate with you, provide you with updates and other information relating to our Services, provide information that you request, respond to comments and questions, and otherwise provide User support;
- For marketing and advertising purposes, including developing and providing promotional and advertising materials that may be relevant, valuable or otherwise of interest to you;
- To detect and prevent fraud, and respond to trust and safety issues that may arise;
- For compliance purposes, including enforcing our Terms of Service or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency; and
- For other purposes for which we provide specific notice at the time the information is collected.
- How We Disclose the Information We Collect
Service Providers. We may disclose any information we collect with service providers retained in connection with the provision of our Services. These companies are only permitted to use this information to help us provide our Services, not for their own purposes.
Our Affiliates. We may disclose your information with our affiliates, subsidiaries, and representatives as needed to provide our Services.
Our Partners. We may use analytics services to collect and process certain analytics data which may also collect information about your use of other websites, apps, and online resources. We may also work with third-party advertising partners. These partners include:
Partner
Description
More Information
We use Google’s services to collect and process analytics data.
We use Facebook’s services to place ads that we think may interest our users and potential users.
We may use LinkedIn’s services to place ads that we think may interest our users and potential users, as well as to advertise openings to potential employees.
Please note that this table may be updated from time to time to provide you with the latest information. For more information about your choices regarding how these partners use your information, see the Your Choices section below.
As Required by Law and Similar Disclosures. We may access, preserve, and disclose your information if we believe doing so is required or appropriate to: (a) comply with law enforcement requests and legal process, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our, or others’ rights, property, or safety. In particular, we may disclose relevant information to the appropriate third parties if you post any illegal, threatening, or objectionable content on or through the Services.
Merger, Sale, or Other Asset Transfers. We may transfer your information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or in which we sell, liquidate, or transfer all or a portion of our assets. The use of your information following any of these events will be governed by the provisions of this Privacy Notice in effect at the time the applicable information was collected.
Consent. We may also disclose your information with your permission.
- Your Choices
Our Communications. From time to time you may receive marketing or other informational email messages from us. You can unsubscribe from our promotional and informational emails via the link provided in the emails. Users may continue to receive administrative messages from us necessary to service User accounts after opting out of receiving promotional messages from us.
Cookies. Most web browsers allow you to manage cookies through the browser settings. Be aware that, if you opt out from and do not agree to the use of certain cookies, your experience on our Services may be diminished and some features may not work as intended depending on the cookie. To find out more about cookies, you can visit www.aboutcookies.org or www.allaboutcookies.org.
Our Partners. Some of our advertising partners are members of the Network Advertising Initiative or the Digital Advertising Alliance. You can visit those organizations’ websites to learn about how you may opt out of receiving web-based personalized ads from their member companies. You can also access any settings offered by your mobile operating system to limit ad tracking. To inquire about your choices regarding our business partners generally, contact us at aneezal.mohamed@cvgrp.com (mailto:aneezal.mohamed@cvgrp.com) and ian.vita@cvgrp.com.
- Third-Party Content
Our Services may contain links to other websites, products, or services that we do not own or operate. We are not responsible for the content provided by, or the privacy practices of, these third parties. Please be aware that this Privacy Policy does not apply to your activities on these third-party services or any information you disclose to these third parties. We encourage you to read their privacy policies before providing any information to them.
- Security
We make reasonable efforts to protect your information by using administrative, technological, and physical safeguards designed to improve the security of the information we maintain and protect it from accidental loss, unauthorized access or use, or any other inappropriate or unlawful processing. However, because no information system can be 100% secure, we cannot guarantee the absolute security of your information.
- Children’s Privacy
We do not knowingly collect, maintain, or use personal information from children under 13 years of age, and no part of our Services are directed toward children. If you learn that a child has provided us with personal information in violation of this Privacy Policy, then you may alert us at aneezal.mohamed@cvgrp.com (mailto:aneezal.mohamed@cvgrp.com) and ian.vita@cvgrp.com.
- International Visitors
Our Services are hosted in the United States and intended for visitors located within the United States. If you choose to use the Services from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the United States for storage and processing. Also, we may transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Services. By using our Services, you consent to the transfer, storage, and processing of your information as described in this Privacy Notice.
- Changes to this Privacy Notice
We will post any adjustments to the Privacy Notice on this page, and the revised version will be effective when it is posted. If we make material changes, we may notify you via a notice posted on our website or other method. We encourage you to read this Privacy Notice periodically to stay up to date about our privacy practices.
- Contact Information
If you have any questions, comments, or concerns about our processing activities, please email us at aneezal.mohamed@cvgrp.com and ian.vita@cvgrp.com. Or you may write to us at:
Legal Department
CVG and/or Aftermarket Truck Parts
Commercial Vehicle Group, Inc. 7800 Walton Parkway New Albany, OH 43054
Last Updated: April 6, 2023
Commercial Vehicle Group, Inc. Detailed US Privacy Notice
- Information for US Residents
We collect Personal Data from US residents and comply with the consumer privacy laws of California, Colorado, Connecticut, Utah, and Virginia (“US Privacy Laws”). This Detailed US Privacy Notice applies to US residents (“users,” “you,” or “your”).
For the purposes of this Detailed US Privacy Notice, “Personal Data” means information that is linked or reasonably linkable to a particular individual or household. However, the following categories of information are not Personal Data:
- Publicly available information;
- Deidentified or aggregated data; or
- Information otherwise excluded from the scope of US Privacy Laws.
This Privacy Notice provides the following information to US residents:
- Categories of Personal Data we collect;
- Purposes for which we use Personal Data;
- Categories of Personal Data we disclose to third parties;
- Categories of third parties to which we disclose Personal Data; and
- How US residents can exercise their rights under US Privacy Laws:
- The rights to access, correct, or delete Personal Data;
- The right to obtain a portable copy of Personal Data;
- The right to limit the use of sensitive personal data in certain circumstances;
- The rights to opt out of targeted advertising, sales of personal data, or profiling; and
- The right to appeal our decisions about your requests.
- Categories of Non-Sensitive Personal Data
The table below outlines the non-sensitive categories of Personal Data Commercial Vehicle Group, Inc. collects about US residents and whether and how they are disclosed to third parties.
We collect Non-Sensitive Personal Data from the following sources:
- Directly from our users
- Inferences from your activity
- From our business partners
- From our processors automatically when you use our website
Category of Personal Data:
Identifiers
Examples
Identifiers may contain the following: now or in the future such basic identifying information as your full name, alias, postal address, e-mail address, phone number, date of birth, account name, signature, username, or other similar identifiers. If you engage with us through social media, we may collect your social media user identifier. Our partner Shopify may collect cookie and or cookie ID's. Device information and other unique identifiers Including device identifier, internet protocol (IP) address, cookies (by Shopify), or similar unique identifiers.
Purpose(s)
To provide or improve products and services such as to fulfill your orders and/or complete the transactions you request through and with the help of our third-party vendors, Shopify, 2Ship and Mode Global; to provide you order updates; general marketing; to communicate with you; to send notifications to you related to your account, email newsletters, promotions, purchases, returns, exchanges, subscriptions, and reservations; to create, maintain, and otherwise manage your account, profile, or possible program membership. We or our partner Shopify, may also use such information for confirmation of purchase location versus customer residence to combat fraud, create geographic market segments for future sales strategies and development of a national demographic. Other purposes may include: security and fraud prevention; fulfillment of legal obligations or core business functions such as the maintenance of records related to business process management, to collect amounts owed, and to provide and maintain the functionality of our website including identifying and repairing errors or problems. Any information collected or processed by 2Ship or its partner MODE is a direct feed from Shopify. 2ship and MODE operate the shipping platform that is integrated with Shopify and receive such order details as recipient name, number, email, address, and product description. This information is used to process and ship your order. All of the above data is stored in Mode billing software (also owned by 2Ship). Mode does not collect any kind of billing information from customer, the 2Ship system simply provides the shipping cost and allows our team to create the shipping labels.
Targeted Advertising
We do not engage in targeted advertising or share this data for targeted advertising purposes
Sale
This data is not sold to third parties
Disclosure
This data may be disclosed to Processors, Affiliates, and Business Partners
Retention Period
We retain this data until the user deletes their account, after which it is retained only to the extent required by applicable law or for purposes of preventing fraud.
Category of Personal Data:
Commercial Data
Examples
Commercial Data may contain the following: consumer history including but not limited to products you have purchased, returned, exchanged, or considered.
Purpose(s)
We may use your purchase history to provide you with offers, suggested products, or to identify other products and offers that may be relevant to you and for other business purposes.
Targeted Advertising
We do not engage in targeted advertising or share this data for targeted advertising purposes
Sale
This data is not sold to third parties
Disclosure
This data is not disclosed to third parties
Retention Period
We retain this data until the user deletes their account, after which it is retained only to the extent required by applicable law or for purposes of preventing fraud.
Category of Personal Data:
Internet/Electronic Activity
Examples
Internet/Electronic Activity may contain the following: your interactions with our services, websites or social media platform; browsing or search history, information on a consumer's interaction with a website, application, or advertisement. Such information may or may not be gleaned from or by our partner vendors Sentry and Google Analytics. Our partner Shopify will collect and use cookies to provide you with a better customer experience. We use Google Analytics to analyze the use of our website and our marketing activities. Google Analytics automatically collects information about users (including IP addresses, cookies and device identifiers). To learn more about Google Analytics or how to opt out, please visit www.google.com/analytics/learn/privacy.html. [specify vendors are processing this information. ]
Purpose(s)
Please note that our processors automatically collect this information when you use our website in order to improve our services; better understand the visitors who come to and make use of our site and what content is of interest to them; other business purposes such as but not limited to the development of a future sales strategies and creation of a national demographic.
Targeted Advertising
We do not engage in targeted advertising or share this data for targeted advertising purposes
Sale
This data is not sold to third parties
Disclosure
This data is not disclosed to third parties
Retention Period
We retain this data until the user deletes their account, after which it is retained only to the extent required by applicable law or for purposes of preventing fraud.
Category of Personal Data:
Imprecise Geolocational Data
Examples
Imprecise Geolocational Data may contain the following: your approximate physical location such as but limited to region or state. This information is a natural byproduct of your use of internet service providers and your provision of billing and shipping addresses to us and our partner Shopify.
Purpose(s)
Fraud prevention; confirmation of purchase location versus customer residence for order confirmation; to create geographic market segments for future sales strategies and development of a national demographic; other business purposes now or in the future.
Targeted Advertising
We do not engage in targeted advertising or share this data for targeted advertising purposes
Sale
This data is not sold to third parties
Disclosure
This data is not disclosed to third parties
Retention Period
We retain this data until the user deletes their account, after which it is retained only to the extent required by applicable law or for purposes of preventing fraud.
Category of Personal Data:
Inferences
Examples
Inferences may contain the following: any information drawn or created from other pieces of Personal Data identified herein.
Purpose(s)
Administration, whether now or in the future, of marketing and personalization functionality or to create a profile about a consumer that reflects their preferences, characteristics, predispositions, behavior and attitudes.
Targeted Advertising
We do not engage in targeted advertising or share this data for targeted advertising purposes
Sale
This data is not sold to third parties
Disclosure
This data is not disclosed to third parties
Retention Period
We retain this data until the user deletes their account, after which it is retained only to the extent required by applicable law or for purposes of preventing fraud.
Category of Personal Data:
Information Collected by Payment Processors
Examples
Information Collected by Payment Processors may contain the following: a range of personal and sensitive financial information collected solely by our E-commerce partner Shopify, including but not limited to: credit or debit card information; Commercial information, including products you purchase, place in your shopping cart, favorite or review (if you are a customer) and information you provide us about you and your business (if you are a merchant); Photos and videos, which may include face imagery, if you choose to provide them. Internet or other electronic network activity information, including information regarding the device and browser you use, network connection, IP address, and how you browse through our apps and sites; Geolocation data, including your mailing and billing address; Inferences, or information derived from other personal information about you, which could include your preferences, interests, and other information used to personalize your experience; Other information you provide; and Sensitive personal information, which may include: Your account access credentials (such as financial account, debit or credit card number in combination with any required security access code, password, or credentials allowing access to an account); Your device’s precise location (if you are a Shop App user, but only when you allow Shop to access this information); Information you voluntarily disclose that may reveal certain characteristics about you such as your racial or ethnic origin or sexual orientation The contents of email messages in the email inboxes that you connect to your Shop account, and information from email messages you transfer to the app to be included in your order history (if you use Shop).
Purpose(s)
To facilitate the sale and shipment of our products to you
Targeted Advertising
We do not engage in targeted advertising or share this data for targeted advertising purposes
Sale
This data is not sold to third parties
Disclosure
This data may be disclosed to Processors and Business Partners
Retention Period
We retain this data until the user deletes their account, after which it is retained only to the extent required by applicable law or for purposes of preventing fraud.
- Categories of Sensitive Personal Data
The table below outlines the categories of Sensitive Personal Data Commercial Vehicle Group, Inc.’s Processors may collect about US residents and whether they are disclosed to third parties. Commercial Vehicle Group, Inc. and our Processors do not directly collect or process Sensitive Personal Data for the purposes to which the right to limit the use and disclosure applies under the CCPA.
Sensitive Personal Data is collected from the following sources:
- From our business partners
Category of Sensitive Personal Data:
Financial Data
Examples
Financial Data may contain the following: Our Processors may collect and process the following categories of Sensitive Personal Data listed below (please see the “Information Collected by Payment Processors” section for more information regarding the processing of Sensitive Person Data): • Your account access credentials (such as financial account, debit or credit card number in combination with any required security access code, password, or credentials allowing access to an account)
Purpose(s)
To facilitate our sale of products to you
Targeted Advertising
We do not engage in targeted advertising or share this data for targeted advertising purposes
Sale
This data is not sold to third parties
Disclosure
This data may be disclosed to Processors and Business Partners
Retention Period
We do not directly collect or retain this data but our Processor will until the user deletes their account, after which it is retained only to the extent required by applicable law or for purposes of preventing fraud
- Use of Personal Data
We use Personal Data for the purposes described above. Personal Data may also be used or disclosed as otherwise permitted or required by applicable law.
- Disclosing Personal Data
We disclose Personal Data to the following categories recipients:
- Processors: We use processors to securely handle Personal Data on our behalf and only on our instructions. These companies may not use your Personal Data for their own purposes.
- Affiliates: We may share your information with our affiliates, subsidiaries, and representatives as part of providing our services.
- Our Business Partners: We may share relevant personal data with our business partners to provide you with exclusive offers for products and services that may interest you.
See the tables above for more details about how different categories of Personal Data are disclosed.
We do not sell Personal Data to anyone.
- Exercising Your Personal Data Rights
US residents have the following rights under US Privacy Laws:
- The rights to access, correct, or delete Personal Data;
- The right to obtain a portable copy of Personal Data;
- The right to limit the use of Sensitive Personal Data in certain circumstances;
- The rights to opt out of targeted advertising, sales of personal data, or profiling; and
- The right to appeal our decisions about your requests if you disagree with them.
If you are a US resident, you can submit a request to exercise your personal data rights under US Privacy Laws by contacting us through our secure request portal at: https://www.requesteasy.com/63f7-9035 . To protect your privacy, we may need to authenticate your identity before we respond to your rights request. We will use commercially reasonable efforts to verify your identity for this purpose. Any information you provide to authenticate your identity will only be used to process your rights request. If you have a password-protected online account with us, we may require you to submit your rights request securely through that account. Please be aware that we do not accept or process rights requests through other means (e.g., via fax or social media).
After submitting your request online, you will receive a follow-up email, which may include a link you must click on in order to verify your identity. If you do not click on that link, we may be unable to complete your request due to lack of verification. It is important that you provide a valid email address in order for us to be able to process your request.
We will respond to your rights request within 45 days, though in certain cases we may inform you that we will need up to another 45 days to act on your request. If we suspect fraudulent or malicious activity on or from your account, we will delay taking action on your request until we can appropriately verify your identity and the request as authentic. Also note that each of the rights are subject to certain exceptions. If you believe our response to your rights request is insufficient, you can appeal our decision by contacting us through our secure request portal at: https://www.requesteasy.com/63f7-9035 and we will inform you of our final decision within 45 days.
We reserve the right to decline to process, or charge a reasonable fee for, requests from a US resident that are manifestly unfounded, excessive, or repetitive.
- Limiting the Use of Sensitive Personal Data
Under the CCPA consumers may have the right to limit some uses of Sensitive Personal Data. Commercial Vehicle Group, Inc. and our Processors do not directly collect or process Sensitive Personal Data for the purposes to which the right to limit the use and disclosure applies under the CCPA.
- Authorized Agent Requests
You may designate an authorized agent to make a rights request on your behalf. Your authorized agent may submit such a request by following the same method described above. We may require verification of your authorized agent in addition to the information for verification above for US residents and households.
- Contact Us
If you have any questions or concerns regarding this Detailed US Privacy Notice, contact us at ian.vita@cvgrp.com; aneezal.mohamed@cvgrp.com.
Last updated: March 29, 2023
