Business Partner Privacy Notice
This Business Partner Privacy Notice (“Notice”) describes how Norman & Company, Inc. and Classic Administration Systems, LLC (“We,” “Us,” “Our”) handle Personal Information in connection with our relationships with dealers, agents, lenders, brokers, third-party administrators, and other business partners (“Business Partners”).
This Notice is intended to supplement, and not replace, any applicable agreements between Us and Our Business Partners.
We recognize that our Business Partners are responsible for maintaining the trust of their customers, including the protection of non-public personal information (“NPPI”), as defined under applicable law, including the Gramm-Leach-Bliley Act (“GLBA”), where applicable. We are committed to supporting that trust by safeguarding information provided to Us in the course of providing our services.
Scope and Role of the Parties
In the course of providing Our products and services, We may receive, collect, or process Personal Information from or on behalf of Our Business Partners.
To the extent We process Personal Information on behalf of a Business Partner, We do so solely for the purpose of providing contracted services, administering applicable programs, and fulfilling operational requirements.
For purposes of this Notice, Business Partners generally act as the data controller or equivalent under applicable privacy laws, and We act as a service provider or processor when processing Personal Information on their behalf.
Business Partners are responsible for ensuring that any Personal Information they provide to Us has been collected and shared in compliance with applicable law.
Information We May Process
Depending on the nature of the services provided, Personal Information may include information related to:
- Customers or end users
- Contracts, agreements, and program enrollments
- Vehicle, product, or service information
- Transaction and claim-related information
- Contact and identification information
- Payment, commission, and incentive-related information
We do not seek to collect or process more Personal Information than is reasonably necessary to perform the services requested by Our Business Partners.
Financial, Tax, and Payment Information
In connection with the administration of commissions, incentives, and program participation, We may collect and process certain financial and tax-related information from Business Partners, agents, sub-agents, and individuals affiliated with dealerships or other participating entities.
This information may include:
- Tax identification numbers (such as EINs or Social Security Numbers, where applicable)
- Completed IRS Forms W-9 or equivalent tax documentation
- Banking and payment information, including account and routing numbers
- Information required to facilitate commission payments, incentive programs, or direct deposit enrollment
We use this information solely for payment administration, tax reporting, regulatory compliance, fraud prevention, and related operational purposes.
Access to this information is restricted to authorized personnel involved in payment processing, compliance, accounting, and program administration.
We do not sell or use financial or tax information for unrelated purposes.
Use of Personal Information
We use Personal Information solely for the following purposes:
- Providing and administering contracted services
- Processing transactions, claims, cancellations, and related requests
- Supporting program operations and customer service functions
- Meeting legal, regulatory, or compliance obligations
We do not use Personal Information for unrelated purposes inconsistent with the services provided to Our Business Partners.
Disclosure of Personal Information
We may disclose Personal Information to:
- Affiliates and authorized service providers
- Third-party vendors assisting in the delivery of services (such as insurance administrators, inspection providers, or support services)
- Regulatory or legal authorities, where required by law
Where We engage subcontractors or subprocessors, We require them to handle Personal Information only as necessary to perform services on Our behalf and to implement appropriate safeguards consistent with this Notice.
All such disclosures are made solely as necessary to provide services, comply with applicable law, or fulfill contractual obligations.
Data Protection and Security
We maintain reasonable administrative, technical, and physical safeguards designed to protect Personal Information against unauthorized access, use, or disclosure.
These safeguards include controls designed to protect both Business Partner data and any non-public personal information (“NPPI”) processed in connection with our services.
Access to Personal Information is restricted to authorized personnel who require such access to perform services on Our behalf or in connection with Our Business Partner relationships.
We will reasonably cooperate with Business Partners, or their authorized representatives, in connection with security assessments, audits, or incident response activities relating to Personal Information processed in connection with our services, to the extent required under applicable agreements or applicable law.
In the event of a security incident involving Personal Information, We will take appropriate steps to investigate the matter and provide notice and reasonable assistance to affected Business Partners as required by applicable law or contractual obligations, including assistance reasonably necessary to support compliance with applicable privacy or security requirements.
We regularly review and update Our safeguards as appropriate to maintain data security and operational integrity.
Data Retention
We retain Personal Information only for as long as reasonably necessary to provide services, fulfill contractual obligations, comply with legal requirements, or resolve disputes.
Upon termination of a business relationship or upon request where applicable, We will delete or return Personal Information in accordance with Our contractual obligations and applicable law, unless retention is required by law.
Business Partner Responsibilities
Business Partners are responsible for:
- Ensuring they have a lawful basis for providing Personal Information to Us
- Complying with applicable privacy and data protection laws, including the Gramm-Leach-Bliley Act where applicable
- Providing appropriate privacy disclosures to their customers or end users
- Maintaining appropriate security safeguards for information under their control
No Sale or Unauthorized Use of Data
We do not sell Personal Information and do not use Personal Information for targeted advertising purposes.
We do not use, disclose, or retain Personal Information for any purpose other than providing contracted services, fulfilling legal obligations, or as otherwise permitted under applicable agreements and law.
Updates to This Notice
We may update this Notice from time to time to reflect changes in Our practices, legal requirements, or business operations. Updated versions will be made available through appropriate business channels or systems.
Contact Information
Questions regarding this Notice or Our data handling practices may be directed to Us using the contact information provided in the applicable agreement between the parties.
Our Mailing address:
Norman and Company, Inc./Classic
13401 McCormick Drive
Tampa, FL 33626
Attention: Compliance Department
Email address: Compliance@classictrak.com
Telephone Number: 800-930-4633
Fax Number: 813-855-4554
This Privacy Policy is effective as of April 2026