• Privacy Policy

    Effective Date: November 1, 2025
    Last Updated: November 1, 2025

    Creative Package McKahan, Inc. (“Creative Package McKahan,” “CPM,” “we,” “us,” or “our”) values privacy and is committed to protecting personal information collected, processed, stored, transmitted, or analyzed in connection with our websites, digital properties, marketing services, advertising campaigns, lead-generation programs, analytics services, customer relationship management services, text messaging and telephone communications, artificial intelligence tools, and related services (collectively, the “Services”).

    This Privacy Policy explains how personal information is collected, used, disclosed, shared, retained, protected, and processed when individuals interact with CPM or CPM’s Clients, including automotive dealerships, dealer groups, manufacturers, and other businesses (“Clients”).

    By accessing or using the Services in any manner — including by visiting a website, submitting a lead form, engaging with an advertisement, communicating by phone or text message, participating in an event, or interacting in-store — you acknowledge and agree to the practices described in this Privacy Policy.

    1. Role of Creative Package McKahan (Service Provider / Processor)

    In many instances, CPM acts as a service provider and data processor on behalf of its Clients under applicable privacy laws, including the California Consumer Privacy Act as amended by the California Privacy Rights Act (“CCPA/CPRA”).

    When acting in this capacity, CPM processes personal information solely for the business purposes specified by its Clients, pursuant to written agreements, and in accordance with applicable law. CPM does not sell personal information and does not use personal information for purposes outside the scope of its contractual obligations, except as permitted by law.

    2. Scope of This Policy

    This Privacy Policy applies to personal information collected:

    • Online and offline

    • Through CPM-managed or Client-managed websites

    • Through advertising platforms and lead forms

    • Through phone calls, SMS/MMS text messages, emails, chats, and messaging systems

    • Through events, promotions, and in-store interactions

    • Through integrations with dealership CRMs, DMS systems, and third-party platforms

    • Through automated systems, artificial intelligence tools, and analytics technologies

    This Policy does not govern information collected independently by a Client outside CPM-managed systems.

    3. Categories of Personal Information Collected

    Depending on interaction, CPM may collect, receive, store, or process the following categories of personal information:

    A. Identifiers and Contact Information

    • Name

    • Email address

    • Telephone number (including mobile, landline, VoIP)

    • Postal address

    • IP address

    • Online identifiers

    • Device identifiers

    B. Automotive-Related Information

    • Vehicle interest, ownership, or service information

    • Vehicle identifiers (make, model, year, VIN)

    • Trade-in information

    • Appointment requests

    • Financing or credit interest indicators (excluding consumer credit reports)

    C. Communication and Interaction Data

    • SMS and MMS message content

    • Phone call recordings, transcripts, and metadata

    • Email communications

    • Chat and messaging transcripts

    • Opt-in, opt-out, and consent records

    • Communication timestamps and source data

    D. Internet and Device Activity

    • Browsing history and interaction data

    • Cookies, pixels, SDKs, and similar technologies

    • Advertising engagement data

    • Analytics and attribution data

    E. Commercial and Transactional Data

    • Products or services requested

    • Offers or incentives viewed or redeemed

    • Lead status and outcome data

    F. Location Information

    • Approximate geographic location (city, ZIP code, region)

    G. Inferences and Derived Data

    • Preferences and interests

    • Predictive insights and behavioral modeling

    • Likelihood to purchase, lease, or service

    • Engagement and response scoring

    4. Sources of Personal Information

    Personal information may be collected from:

    • You directly

    • CPM-managed or Client-managed digital properties

    • Advertising and social media platforms

    • Dealership CRMs and DMS systems

    • Call centers and business development centers

    • Third-party data providers

    • Events, promotions, and contests

    • Automated tracking technologies

    • Artificial intelligence and analytics tools

    5. Consent to Communications (SMS, MMS, Calls, Email)

    A. Express Consent

    By providing your contact information or interacting with the Services, you expressly consent to receive communications from CPM and/or CPM’s Clients, including:

    • SMS and MMS text messages

    • Telephone calls (including autodialed and prerecorded messages)

    • Emails and other electronic communications

    Messages may be sent using automated or artificial intelligence-enabled technologies and may relate to vehicle sales, leasing, service, appointments, promotions, customer service, or marketing communications.

    Consent is not a condition of purchase.

    B. Opt-Out Rights

    You may opt out of SMS messages at any time by replying STOP, END, CANCEL, UNSUBSCRIBE, or similar commands. You may opt out of emails using the unsubscribe mechanism provided.

    Opt-out requests will be honored in compliance with applicable law. Message and data rates may apply.

    C. Recordkeeping

    CPM and its Clients maintain records of consent, including method, timestamp, source, and communication activity, to meet legal, carrier, and regulatory requirements.

    6. Use of Artificial Intelligence and Automated Technologies

    CPM may use artificial intelligence, machine learning, automation, and algorithmic tools in connection with the Services, including for:

    • Call recording, transcription, and analysis

    • Message generation, routing, and optimization

    • Lead scoring, enrichment, and prioritization

    • Performance measurement and attribution

    • Fraud prevention and quality assurance

    • Predictive modeling and analytics

    These tools may process personal information in accordance with this Privacy Policy and applicable law. AI outputs may be reviewed by human personnel.

    7. Purposes for Using Personal Information

    Personal information may be used for purposes including:

    • Providing and operating the Services

    • Lead delivery and routing to Clients

    • CRM integration and management

    • Marketing, advertising, and promotions

    • Communication via phone, text, and email

    • Analytics, reporting, and optimization

    • Legal and regulatory compliance

    • Security, fraud prevention, and auditing

    • Business operations and improvement

    8. Sharing and Disclosure of Personal Information

    Personal information may be disclosed to:

    • Automotive dealerships and Clients

    • CRM, DMS, and software providers

    • Messaging and telecommunications providers

    • Advertising and analytics platforms

    • Call centers and service vendors

    • Cloud hosting and security providers

    • Legal, regulatory, or governmental authorities

    • Successor entities in corporate transactions

    CPM does not sell personal information as defined by California law.

    9. California Privacy Rights (CCPA / CPRA)

    California residents have the right to:

    • Know what personal information is collected, used, and disclosed

    • Access personal information

    • Request deletion or correction (subject to legal exceptions)

    • Limit use of sensitive personal information

    • Opt out of targeted advertising or data sharing

    • Not be discriminated against for exercising rights

    Requests may be submitted to info@cpmckahan.com. Verification may be required.

    10. Data Retention

    Personal information is retained only as long as reasonably necessary to fulfill business, legal, and contractual obligations, or as required by law.

    11. Data Security

    CPM maintains reasonable administrative, technical, and physical safeguards designed to protect personal information. No system is completely secure.

    12. Third-Party Platforms

    CPM is not responsible for the privacy practices of third-party websites, platforms, or services linked to or integrated with the Services.

    13. Children’s Privacy

    The Services are not intended for individuals under the age of 13, and CPM does not knowingly collect personal information from children under 13.

    14. Changes to This Privacy Policy

    This Privacy Policy may be updated periodically. Updates will be effective upon posting with a revised effective date.

    15. Contact Information

    Creative Package McKahan, Inc.
    Email: info@cpmckahan.com

    16. Acknowledgment

    By using the Services, you acknowledge that you have read, understand, and agree to this Privacy Policy.