Introduction

At Endras Automotive Group (“Endras”) we are committed to your privacy. This means we do not distribute, transfer, disclose, rent or sell any of your personal information to third parties except as provided for in this policy (the “Privacy Policy”) or as specifically consented by you.

Endras has developed policies and procedures consistent with the Personal Information Protection and Electronic Documents Act (“PIPEDA”), and other relevant privacy laws.

Scope

This Privacy Policy applies to all personal information (“Personal Information”) collected, used or disclosed by Endras. Personal Information means any information about you except your name, business title, business address and business telephone number if you are an employee of a business. It also does not include your home address and telephone number if these are published in a telephone or other directory and you had the opportunity to refuse to have your information listed.

Accountability

Endras is responsible for the Personal Information under our possession and control. We have designated a Privacy Officer to be responsible for our compliance with this Privacy Policy and privacy legislation.

What Personal Information Do We Collect?

When you purchase or lease a vehicle from Endras, or when you have us service or repair a vehicle, purchase or lease other products or services from us, participate in one of our surveys, contests, or promotions, test drive one of vehicles, contact or meet with one of our dealership staff, we may collect some or all of the following Personal Information:

your name, address and telephone number;

your email address and facsimile number;

your occupation;

information about your driving habits (such as preferred vehicle size, colour, type of vehicle, driving habits, etc.);

information about your existing vehicle(s) and any trade-in;

details of your vehicle, its odometer reading, 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;

your language preference;

your date of birth;

your social insurance number; and

financial and credit information about you (specific information is set out in the application for credit forms).

What information do we collect electronically?

For users of our website (the “Website”), Endras automatically receives and stores certain types of non-personally identifiable information including IP address, web pages viewed, date and time, and responses to advertisements delivered by Endras or third-party ad serving technologies. While each advertising technology uses different types of technology to collect this information, including log files, cookies and pixels, none of the foregoing by itself or together can be tracked to a specific individual’s personally identifiable information, and the non-personally identifiable information collected by Endras will not be shared with third parties except as expressly indicated in this Privacy Policy. By visiting the Website, third party companies contracted by Endras may place cookies on your browser for the purposes of targeting relevant advertising to you across the Website and other websites. Check your browser’s help section for instructions on how to reject or manage first party (i.e. Endras) and/or third-party cookies.

Use of non-personally identifiable information

The non-personally identifiable information collected through your use of the Website is used (1) to provide relevant, targeted advertising; monitor website traffic; (2) collect statistical data; (3) determine the effectiveness of advertisements and content; and (4) collect data across multiple websites to categorize likely consumer interest segments for use in online behavioural advertising (“OBA”). To opt out of receiving targeted advertising, visit optout.networkadvertising.org and follow the instructions.

How do we use your Personal Information?

Endras collects Personal Information for the following purposes:

to provide products and services to you;

to obtain a credit report if you are financing or leasing your vehicle;

to assist in obtaining appropriate financing of your vehicle to you;

to administer your vehicle warranty coverage;

to provide you with vehicle service reminders;

to establish and maintain responsible commercial relations and to communicate with you in order to provide service. This includes, but is not limited to, communications relating to advertising, promotion and update and information regarding our products and services;

to respond to any correspondence you may direct to us;

to understand our customers’ needs and preferences;

to direct advertisements to you about goods and services of interest to you;

to meet legal and regulatory requirements; and

for any other reasonable purposes for which you may have provided your express consent or in which your consent can be reasonably implied.

Consent

We respect your privacy and, unless otherwise required by law, we will not collect, use or disclose your Personal Information without your prior consent. Your consent may be expressed or implied. You may expressly give your consent in writing, verbally or through any electronic means. In certain circumstances, your consent may be implied by your actions. For example, providing us Personal Information relevant to servicing your vehicle is implied consent to use such information to provide you the associated services.

Where appropriate, Endras will generally seek consent for the use or disclosure of the information at the time of collection. In certain circumstances, consent with respect to use or disclosure may be sought after the information has been collected but before use (for example, when Endras wants to use information for a purpose other than those identified above). In obtaining consent, Endras will use reasonable efforts to ensure that a customer is advised of the identified purposes for which Personal Information collected will be used or disclosed.

The form of consent sought by Endras may vary, depending upon the circumstances and type of information disclosed. In determining the appropriate form of consent, Endras shall take into account the sensitivity of the Personal Information and the reasonable expectations of our customers. Endras will seek express consent when the information is likely to be considered sensitive. Implied consent will generally be appropriate where the information is less sensitive.

You consent that your personal information and demographic information, excluding your payment information, will be used to provide you with targeted advertising based on your previous purchases, demographic data, and location.

We may also use demographic information and personal contact information, excluding transactional information, to contact you about changes, enhancements or other notices related to products or services you requested from us or which we provide. In addition, we may use this information to provide you with more targeted offers, advertising, information and content (including offers and other information that has been supplied by our affiliates and selected sponsors or advertisers), including on websites you visit ("Marketing Offers"). If you do not wish to receive Marketing Offers, you may opt-out at any time by following the opt-out procedure below.

We may also collect, use and store your current location or a history or location preferences or settings to establish your location, improve your experience and, from time to time, to send you information, such as Marketing Offers, that is most relevant to your geographic location. You may manage how your mobile device and mobile browser share location information with us, as well as how your mobile browser handles cookies and related technologies, by adjusting your mobile device privacy and security settings. Please refer to instructions provided by your mobile services provider or the manufacturer of your device to learn how to adjust your settings.

If you register on our Website using any social media login credentials, such as Facebook, you agree that we may collect, use and disclose your information from the social media account for the purpose of fulfilling your request for information, products or services, to respond to your inquiries, to gain a better understanding of your interests so that we may improve our products and services and develop new products and services, to determine your eligibility for other products and services, to contact you about changes, enhancements or other notices related to products or services you requested from us or which we provide, or to provide you with Marketing Offers. Our access to your personal information will vary according to the particular social media credentials used. Please refer to the privacy settings of the social media website or application to determine how you may adjust our permissions and manage the interactivity between the Endras and your social media account.

Cookies and Online Behavioral and Location-Based Advertising

We also may automatically collect general anonymous information related to your use of the Website(s), such as the date and time you visited the Website(s) and the pages you visited on the Website(s). In addition, we collect “cookie” information from your browser to identify your computer and provide us with a record of your visits to our Website(s). A cookie is a small text file that is stored on your internet browser and that can collect and store information. This statistical information helps us to understand how our Website(s) is used (e.g. which pages or sections are most popular and when are the peak activity times) and assists us in planning for future improvements to the Website(s) to better meet our visitors’ needs.

We may place advertising or other links on our Website that originate from outside advertisers and other third parties, specifically from the Adroll platform. If you view these ads, the advertisers may assign or recognize cookies. Endras does not control these cookies, nor is it responsible for any marketing or other use of your information by these advertisers or other third parties.

Our Website uses third-party advertising companies to serve ads when you visit the Site. These companies may use information (such as web pages you visit and your response to ads but not including your name, address, email address or telephone number) about your visits to this and other websites in order to provide advertisements about goods and services that may be of interest to you. Some ads appearing on our Website are delivered to you by Adroll, which is a web advertising company. These third parties may, from time to time, use information that they collect about your visits to the Website, such as the number of times you have viewed an ad (but not your name, address, email address or telephone number) to serve additional ads about goods and services that may be of interest to you. We may also use IP (Internet protocol) addresses to display or allow our third party advertising providers to display more targeted advertising and content. If you do not wish to have your information used in this way, please click on the following link: http://www.aboutads.info/. The following link has useful information about how to opt out of cookies that are placed by companies who are members of the network NAI (Network Advertising Initiative): http://www.networkadvertising.org/choices/ For more information on online behavioral advertising or to opt-out from other third-party advertising companies, visit the Digital Advertising Alliance of Canada website at youradchoices.ca

We may, from time to time, track and analyze anonymous usage and browsing patterns of visitors to our Website to provide our advertisers with more targeted advertising opportunities and to help users see advertising that is most likely to interest them. We may use third party analytics service providers in order to gather such anonymous data on user behavior, including Google Analytics, which uses data as described in the following link: https://www.google.com/policies/privacy/partners/

We and our third party service providers such as Adroll may, from time to time, use cookies, web beacons and other technologies to track and analyze certain information about user behavior and interaction with our Website, websites operated by our affiliates or websites that are a part of our service provider’s networks (such as browser version and name, how you were directed to the relevant website, or to register with us, page views, date and time of registration or installation, push notification subscription status, push notification engagement activity, details with respect to use of mobile applications and their functionality) and with e-mails we send to you (such as open and click activity), and about your device (such as device model and type, and OS version and name). We may use third party analytics service providers in order to gather such data on user behavior, and to provide us with other data collection, reporting, ad response measurement and site analytics. This information is used to improve your experience, to help us develop new products and services, to gain a better understanding of your interests so that we may develop new products and services, to determine your eligibility for other products and services, and to provide you with customized advertising, customized content and Marketing Offers that we believe may be of particular interest to you. These third party service providers may also collect and use certain aggregated or anonymized information, which is subject to their own privacy policies.

Limiting Use, Disclosure and Retention

Unless required by law, or in connection with a business transaction, Endras shall not use or disclose or transfer Personal Information for any purpose other than those described above without first identifying and documenting the new purpose and obtaining your consent, where such consent may not reasonably be implied.

As noted above, Endras does not disclose your Personal Information to third parties excepted as provided for in this Privacy Policy. We may share some or all of your Person Information to other Endras Dealers and with third parties such as: the providers of products or services for 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 transfer your Personal Information to third party suppliers, contractors and agents (“Affiliates”) who are contracted by Endras to assist it in providing and developing products and services. Such Affiliates will only use your Personal Information for the purposes identified above. We may also share your Personal Information with the car manufacturer or the manufacturer’s financing branch (for example, should you require financing for a vehicle purchased from Endras BMW we would need to disclose your Personal Information to BMW Group Financial Services Canada).

In the event your Personal Information is disclosed to a third party pursuant to a business transaction, Endras will ensure that it has entered into an agreement under which the collection, use and disclosure of the information is related to those purposes that relate to the transaction.

Subject to the foregoing, only Endras’ and our Affiliates’ employees with a business need to know, or whose duties reasonably so require, are granted access to your Personal Information. All such employees will be required as a condition of employment to contractually respect the confidentiality of your Personal Information.

Endras will retain Personal Information for only as long as required to fulfill the identified purposes or as required by law. Personal Information that is no longer required to fulfill the identified purposes will be destroyed, erased or made anonymous according to the guidelines and procedures established by Endras.

Most of our uses of your Personal Information are necessary for us to sell or lease you your vehicle, assist you in the financing or lease of your vehicle or provide service to your vehicle and we cannot do this without your Personal Information. Similarly, we must disclose your Personal Information for many of the purposes described above, for example to assist you in arrangements for financing. If you do want us to use or disclose your Personal Information in a particular way, please contact our Privacy Officer and we will be pleased to discuss with you how we can limit our use or disclosure of your Personal Information.

How can I access my Personal Information?

Upon request, Endras will provide you information regarding the existence, use and disclosure of your Personal Information and you will be given access to that information. Endras will respond to an application for individual access to Personal Information within a reasonable time and at minimal or no cost to the individual.
You may challenge the accuracy and completeness of the information and have it amended as appropriate.

NOTE: In certain circumstances, Endras may not be able to provide access to all your Personal Information it holds. Exceptions may include information that is prohibitively costly to provide, information that contains references to other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons, or information that is subject to solicitor-client or litigation privilege. Endras will provide the reasons for denying access upon request.

Safeguards

Endras protects your Personal Information by security safeguards appropriate to the sensitivity of the information. Endras will protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification.

Opting-out.

In general, when you provide us with your personal information, we rely upon your implied consent to our collection, use and disclosure of such information for the purposes identified or described in this Privacy Policy or, if applicable, otherwise at the time of collection. We obtain your express opt-in consent to use or disclose sensitive personal information.

If you do not wish to receive Marketing Offers, or do not wish for Endras to use your personal information for any behavioral or location-based advertisements, you may opt-out at any time by doing any of the following:

-Follow the instructions at the bottom of any email Marketing Offer you receive.

-Opt-out from Adroll by visiting the following links: http://www.networkadvertising.org/choices or http://www.aboutads.info/

-Email at ivy @ endrasautomotivegroup.com and request that your personal information not be used for Marketing Offers or for behavioral or location-based advertisements.

It may take 2-4 weeks to fully process your opt-out request. Please note that if you opt-out of receiving Marketing Offers, you may continue to receive certain transactional messages from us.

We reserve the right to use and disclose your personal information without your consent where required or permitted by law, for example, if we have reasonable grounds to believe the information could be useful when investigating a contravention of a federal, provincial or foreign law, in order to protect or defend our legal interests, or to comply with applicable laws and lawful governmental requests.

If you choose to opt-out of any use of your personal information in accordance with our opt-out policy, we will keep your contact information and details with respect to your opt-out on a list so that your request can be honored, and we may retain your information to fulfill legal or regulatory obligations or for other purposes permitted by law.

Our methods of protection include:

Physical measures, such as filing cabinets which are kept locked when not in use and restricted access, both to Endras’s place of business in general and to internal offices as well;

Organization measures, such as security clearances and limited access on a need to know basis; and

Technological measures, such as the use of passwords, firewalls and encryption.

Challenging Compliance

An individual will be able to address a challenge concerning compliance with this Privacy Policy to Endras’s Privacy Officer.

Endras will maintain procedures for addressing and responding to all inquiries or complaints from its Members about Endras’s handling of Personal Information. Endras shall investigate all complaints. All inquiries or complaints involving Endras’s handling of Personal Information or compliance with this policy or with PIPEDA shall be directed to Endras’s Privacy Officer.

The Privacy Officer will respond to all such inquiries or complaints within 14 business days of receipt. The Privacy Officer will make reasonable efforts to resolve all such complaints within 30 days of receipt of the initial complaint. If Endras finds a complaint to be justified, it will take appropriate measures, including, if necessary, amending its policies and procedures.

For more information, please contact our Privacy Office as follows:

E-mail: ivy@endrasautomotivegroup.com

Mail:

Privacy Officer: Ivy Wang

Endras Automotive Group

100 Achilles Rd, Ajax, ON

L1Z 0C5

General

Endras reserves the right to modify and amend this privacy policy from time to time in its sole discretion without prior notice. Any such amendment(s) will be posted on our Website and will be effective as of the date of posting.