PROTECTION OF YOUR INFORMATION
Application and Scope
Definition of Personal Information
Collection and Use of Personal Information
We collect most of our information about you directly from you, with your consent when required by law. For example, when you take a test drive, online request an appointment or vehicle quote, purchase or lease a vehicle, or service your vehicle, DEALER will collect information about you. We may also conduct contests, quizzes, surveys, promotions and offer several forms of personalized services such as vehicle warranty, servicing and maintenance and OnStar services, in respect of which you may be requested to provide personal information, such as name, mailing address, telephone number, e-mail address, age and other information that may be required to provide or administer these services or promotions.
[We may also obtain personal information about you from third parties, with your consent. For example, for credit evaluation purposes, we may need to determine your creditworthiness through contact with an independent credit reporting agency.]
DEALER generally collects personal information from or about its customers and other individuals with whom it deals, and thereafter uses it, for the following purposes:
- to establish, develop and preserve its business relationship respectively with its customers and other individuals with whom it deals;
- to create, establish and administer customers’ accounts and to respond to customer or supplier inquiries;
- to provide the products or services that it offers, or receive the products or services that it requests, and ensure that all related transactions are supported and implemented;
- to authenticate the identity and preserve the privacy of customers contacting DEALER by telephone, electronic means or otherwise;
- to conduct market analysis, as well as for internal training and quality assurance purposes;
- [as necessary, to establish or verify the credit of persons that use, or intend to purchase, one or more of the products or services offered by DEALER;]
- to manage its General Motors Dealer business and ensure the efficiency, reliability and security of its systems and networks;
- to meet legal and regulatory requirements and allow DEALER to meet contractual requirements relating to the products and services provided to customers;
- to ensure its records are accurate and to protect customers and DEALER from error and fraud;
- to understand and assess the interests, wants and changing needs of customers with a view to improving its products and services and developing new ones;
- to provide personalized products and services as well as product recommendations to customers; and
subject to our customers’ Right to Withdraw Consent, to conduct surveys on the quality of our products, services or customer service or to provide our customers with offers for additional products and services that we feel may be of interest to our customers or that we believe meet our customers’ changing needs.
If you have applied for employment with DEALER, the personal information submitted with your job application will be used for recruitment and other customary human resources purposes. For example, we may send you information about new job opportunities within DEALER as well as other career development resources.
DEALER obtains consent from the individuals concerned for the collection, use or disclosure of personal information through various means: orally or through written documents, including agreements, forms including vehicle purchase/leasing forms and repair orders, welcome kits as well as printed or electronic communications. The form of consent sought by DEALER will vary according to the sensitivity of the personal information, the reasonable expectations of the individuals and any requirements or standards established by law.
In certain circumstances, personal information may be collected, used or disclosed without consent. These exceptional circumstances may include:
- where it is clearly in the interest of the individual and consent cannot be obtained in a timely way, such as in emergencies, where the life, health or safety of the individual is threatened, or where legal, medical or security reasons make it impossible or impractical to obtain consent;
- when information is being collected, used or shared for the detection, prevention of or remediation to, the breach of an agreement, fraud or other illegal activity, and the collection of consent might defeat the purpose of collecting the information;
- to collect a debt; and
- to comply with a subpoena, warrant or other court order, or as may be otherwise required or authorized by law or by any regulatory bodies having jurisdiction.
Right to Withdraw Consent
Consent may be withdrawn at any time, subject to legal or contractual restrictions and reasonable notice; however, without such consent, DEALER may be limited in the services or products it is able to provide customers. You may also withdraw your consent as follows:
- Mail marketing, Telephone marketing and Quality control communications. You may decide that you prefer DEALER not to use your personal information to promote new and/or additional products and services which may be of interest to you and refuse further DEALER contact by mail or telephone for marketing purposes or by email or telephone for quality control purposes. If this is the case, you may advise us by contacting customer service or contacting us using the information detailed in the How to Contact Us section below.
- Commercial Electronic Communications. You can always limit the communications that DEALER sends to you. To opt-out of commercial emails, simply click the link labeled “unsubscribe” or “opt-out” at the bottom of any commercial electronic communication we send you. Please note that even if you opt-out of promotional communications, we may still need to contact you with important information about your account or for other purposes as may be permitted or required under applicable laws. If you have any questions about your choices or if you need any assistance with opting-out, please contact us using the contact information detailed in the How to Contact Us section below.
Sharing of Personal Information
- Third party or affiliated service providers. We may hire service providers, which may be affiliates, to perform services on our behalf. This may include, without limitation, a person or an organization retained by DEALER to perform work on its behalf. We provide them with a limited amount of information which is necessary in order for them to provide the services required. They are prohibited from using the information for purposes other than to facilitate and carry out the services they have been engaged to provide. These service providers are not permitted to disclose this information to others.
- As permitted or required by law. From time to time, DEALER may be compelled to disclose personal information in response to a law, regulation, court order, subpoena, valid demand, search warrant, government investigation or other legally valid request or enquiry. We may also disclose information to our accountants, auditors, agents and lawyers in connection with the enforcement or protection of our legal rights. We also reserve the right to report to law enforcement agencies any activities that we, in good faith, believe to be unlawful or to law enforcement and emergency services providers, in an emergency or where required or permitted by law. We may release certain personal information when we have reasonable grounds to believe that such release is reasonably necessary to protect the rights, property and safety of others and ourselves, in accordance with or as authorized by law.
DEALER generally collects and uses personal information from or about its website visitors and users as follows:
- Information you provide. In many cases, we collect personal information directly from you when you visit or use our website. For instance, we may collect the following types of information:
- Technical information. When you visit our website, we may use electronic means such as cookies to collect technical information. This information may include information about your visit to our website, including the IP address of your computer and which browser you used to view our website, your operating system, resolution of screen, location, language settings in browsers, the site you came from, keywords searched (if arriving from a search engine), the number of page views, information you entered, advertisements you have seen, etc. This data is used to measure and improve the effectiveness of our website or enhance the experience for our customers. For instance, it may be used to ensure that the products advertised on our website are available in your area or that we are not showing you the same ads repeatedly. We treat this information as personal information when it is associated with your account or contact information. We also collect and use the following information when you visit and/or interact with us on our website:
Google Analytics: We use Google Analytics which allows us to see information on user website activities including, but not limited to, page views, source and time spent on our website. This information is depersonalized and is displayed as numbers, meaning that it cannot be tracked back to individuals. You may opt-out of our use of Google Analytics by visiting the Google Analytics opt-out page.
[Google AdWords: We use Google AdWords Remarketing to advertise DEALER across the Internet and to advertise on third party websites (including Google) to previous visitors to our website. AdWords remarketing will display ads to you based on what parts of the DEALER website you have viewed by placing a cookie on your web browser. It could mean that we advertise to previous visitors who haven’t completed a task on our site or this could be in the form of an advertisement on the Google search results page, or a site in the Google Display Network. This cookie does not in any way identify you or give access to your computer or mobile device. The cookie is only used to indicate to other websites that you have visited a particular page on our website, so that they may show you ads relating to that page. If you do not wish to participate in our Google AdWords Remarketing, you can opt out by visiting Google’s Ads Preferences Manager].
[Behavioral Advertising.DEALER does not allow third party cookies on its website for purposes of delivering third parties advertising based on preferences or interests known or inferred from the data collected for advertising purposes (often referred to as Online Behavioral Advertising or OBA).]
Personal Information Outside of Canada
In some cases, personal information that we manage may be transferred, processed and stored outside Canada, and therefore may be available to government authorities under lawful orders and laws applicable outside of Canada. DEALER will strive to protect personal information disclosed to third parties by contractual agreements requiring that those third parties adhere to confidentiality and security procedures and protections that are, at a minimum, equivalent to those employed by DEALER itself.
Security of Personal Information
We will use reasonable security measures to protect your personal information against unauthorized access. DEALER has implemented security measures that contain administrative, technical and physical controls that are designed to safeguard your personal information.
Personal information will be retained only as long as necessary for the fulfilment of the purposes for which it was collected and for which consent was received, unless otherwise required or permitted by law. Personal information that is no longer required to fulfil the identified purposes or for a purpose required or permitted by law, will be destroyed, erased or made anonymous. DEALER has developed and implemented retention procedures, and will ensure destruction of personal information in a method that prevents improper access.
Access and Correction
DEALER respects your right to access and correct your personal information. If you need assistance updating your personal information, please contact us using the contact information detailed in the How to Contact Us section below.
How to Contact Us
THOMAS Pontiac Buick GMC Ltd.
Thomas Pontiac Buick GMC Ltd. means Thomas Pontiac Buick GMC Ltd., Thomas GM, Thomas Pontiac and/or Thomas.
Personal Information: means any information about you except your name, business title, business address, business email address, business telephone number or business facsimile number. It also does not include your home address and telephone if these are published in a telephone or other directory.
We are responsible for the personal information under our control and we have designated our Privacy Officer who is responsible for our compliance with this policy and with privacy legislation. If you wish to contact our Privacy Officer:
- by telephone- (905)-372-5447
- by facsimile- (905)-372-4874
- by email- email@example.com
- by mail- P O Box 458, Cobourg, ON, K9A 4L1
What Personal Information do we Collect?
When you purchase or lease a vehicle from us, when you have us service or repair a vehicle, if you finance the purchase or lease of a vehicle through us, purchase or lease other products or services from or through us, if you participate in one of our surveys, contests, or promotions, if you test drive one of our vehicles or contact our dealership staff, we may collect some or all of the following personal information:
- your name, address and telephone number
- email address and facsimile number
- your occupation
- information about your driving habits (such as preferred car size, colour, type of vehicle, kilometers driven annually, etc.)
- information about your existing vehicle(s) and any trade-in
- details of your vehicle and its service history
- your driver’s licence number
- the name of your insurance company and agent
- your insurance policy number and details about your insurance coverage
- similar information about other members of your family
- your language preference
- your date of birth and/or the date of birth of other members of your family
- your social insurance number and/or the social insurance number of other members of your family
- financial and credit information about you and/or other members of your family (specific information is set out in the application for credit forms)
- the principle amount of your loan, interest and repayment schedule
- health information if you apply for life, health, disability or accident insurance
- the amount of any life, health, disability or accident insurance and details of that insurance
Provision of your social insurance number is optional. However, you should be aware that most credit reporting agencies use the social insurance number as a unique identifier to ensure proper identification when conducting credit reviews and preparing credit reports. If you do not wish to provide your social insurance number, our ability to obtain a timely and accurate credit report may be affected.
The Security of your Personal Information is Important to Us
Your personal information is used by us only for the purposes identified below and access to your personal information is limited to those employees of Thomas Pontiac Buick GMC Ltd. who need access to it.
How do We use your Personal Information?
Your personal information may be used by us to provide products and services to you such as licence your vehicle, obtain credit report if you are financing or leasing your vehicle, obtain appropriate financing of your vehicle for you, provide a reminder that your vehicle requires servicing and provide you with updates and information regarding products and services that we have to offer and which we think will be of interest to you.
Sometimes we have to Share your Personal Information with Others
We do not sell your personal information to third parties. We may share some or all of your personal information with third parties such as the manufacturer of your vehicle and its related companies, the providers of products and services relating to your vehicle, credit reporting agencies, financial institutions or financing companies, your insurance agent or company and companies which provide or insure warranties relating to your vehicle. We may also disclose your personal information where we are required or permitted by law to do so.
How Long do we Keep your Personal Information?
We retain your personal information as long as we believe that you are still the owner of the vehicle. If the information relates to the financing or lease of the vehicle, we retain personal information relating to the financing or lease arrangements as long as those arrangements are in place. If the information relates to the service or repair of your vehicle we retain the personal information for as long as is reasonably necessary to address any issues arising from the service or repair of the vehicle or as may be required by law. If there are legal requirements relating to the period of time which we must retain your personal information, we comply with those requirements. Most information is kept for 10 years.
What can you do if you want to Limit the Use to which we put your Personal Information?
Most of the personal information which we collect is necessary for us to sell or lease you your vehicle, to provide products and services related to the vehicle, assist you in the financing or lease of your vehicle or to provide service to your vehicle and we cannot do this without that personal information. Similarly, we must disclose your personal information as described above in order to sell you the vehicle, to provide products and services related to the vehicle, assist you in arrangements for financing or leasing or to provide servicing to your vehicle. If you do not want us to use or disclose your personal information in a particular way, please contact our Privacy Officer as described above and we will be pleased to discuss with you how we can limit collection, use or disclosure of your personal information.
You can Request Access to Your Personal Information
You have a right to access the personal information which we have about you and to request that personal information which you believe to be inaccurate be corrected. If you wish to access your personal information you should contact our Privacy Officer who will be pleased to assist you.