Privacy Policy
ACCEPTANCE OF THIS PRIVACY POLICY
Effective: April 20, 2021
{name} (“we”, “us” or “our”) values its relationship with you and is committed to maintaining the privacy and security of information we receive about you. We have developed this privacy policy (this “Privacy Policy”) to inform you about how we collect, use, disclose and protect the personal information of our customers, potential customers and website users (“you”), and to describe the types of information we may collect from you or that you may provide to us.
We and Subaru Canada, Inc. (“SCI”), the distributor of Subaru brand vehicles in Canada, necessarily share your information with each other in order to provide you with Subaru vehicles, products and services and to ensure your entire Subaru experience, from start to finish, is seamless.
Accordingly, when you access or use {domain} (this “Website”), purchase or lease a Subaru vehicle, purchase other Subaru products and services, or otherwise interact with us, you accept the terms of this Privacy Policy and SCI’s General Privacy Policy.
We do not knowingly collect personal information directly from children under the age of 13; this Website is for general audiences and is not specifically targeted to or intended for use by children.
We will only use your personal information in accordance with this Privacy Policy unless otherwise required by applicable law. We take steps to ensure that the personal information that we collect about you is adequate, relevant, not excessive, and used for limited purposes. Privacy laws in Canada generally define "Personal Information" as any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person.
We may modify this Privacy Policy from time to time and will notify you by posting the revised Privacy Policy on this Website with a new effective date. Your continued use of this Website or our services after any modification to this Privacy Policy will constitute your acceptance of such modification. This Privacy Policy is incorporated into and considered a part of our Website Terms of Use, located at {domain}/en/terms-of-use (the “Terms”).
KEY ELEMENTS OF THIS PRIVACY POLICY
WHAT INFORMATION WE COLLECT
We may collect and use several types of information from and about you, including:
- Personal Information, that we can reasonably use to directly or indirectly identify you, such as your name, mailing address, email address, telephone number, user name or other similar identifier, billing and account information, and any other identifier we may use to contact you online or offline.
- Non-personal information is information that does not directly or indirectly reveal your identity or directly relate to an identified individual, such as demographic information, or statistical or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from Personal Information. For example, we may aggregate Personal Information to calculate the percentage of users accessing a specific Website feature.
- Usage information, including your login information, your Internet Protocol (IP) address used to connect your computer to the Internet and the general geographic location associated with your IP address known as IP geolocation, browser type and version, time zone setting, browser plug-in types and versions, operating systems and platforms, or information about your Internet connection, the equipment you use to access the Website, and usage details.
- Non-personal details about your Website interactions, including the full Uniform Resource Locators (URLs), click stream to, through and from our Website (including dates and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, or any phone number used to call our customer service number.
HOW WE COLLECT YOUR INFORMATION
Information You Provide to Us
The information we collect directly from you may include:
- In-Store: When you visit one of our stores, we may ask you for certain information while you interact with one of our representatives. This may include contact information, payment information, product information and other information you provide when you purchase a vehicle or service from us, and when you finance your lease or purchase through our partners, including your name, email address, address, phone number and financial information.
- Online Accounts: If you sign up for an online account through the Website, we may ask you to provide your username, password, email address, phone number, payment card information, product preferences, past purchases.
- Marketing Communications: If you would like to receive marketing communications from us, you may do so by signing up on the Website or in our stores. We will ask you to provide your email address or phone number so we can send you marketing materials.
- Communicating with us: When you contact us about a customer service issue, or to make other inquiries, we collect the content of those communications, and any additional information about the method of communication such as phone, SMS, email, chat, or through social media platforms. For example, if you email us, we will collect your email address, if you send us a text message, we will collect your phone number, and so on.
- Loyalty & Rewards Programs: If you enroll in a loyalty or rewards program, we collect information such as your name, email, telephone number, or mailing address in order to track your rewards and allow you to redeem them across our brands.
- Other information you provide online: This includes information provided when you subscribe to our service, post material, or request further services, such as a quote. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Website.
Information We Collect While You Interact With Us Through Cookies and Other Automatic Data Collection Technologies
- As you navigate through and interact with the Website, we may use cookies or other automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including: details of your visits to the Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website as well as information about your computer and Internet connection, including your IP address, operating systems, and browser type.
- We may also use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioural tracking). To learn more or to opt out of tailored advertising, please visit Digital Advertising Alliance of Canada Opt-Out Tool for information on how you can opt out of behavioural tracking on this Website and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioural tracking.
- The information we collect automatically is statistical data and does not include Personal Information. However, we may maintain it or associate it with Personal Information we collect in other ways that you provide to us, or receive from third parties. It helps us to improve the Website and to deliver a better and more personalized service, including by enabling us to: estimate our audience size and usage patterns, store information about your preferences, allowing us to customize the Website according to your individual interests, speed up your searches and recognize you when you return to the Website.
The technologies we use for this automatic data collection may include:
- Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of the Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to the Website.
- Flash Cookies. Certain features of the Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on the Website. Flash cookies are not managed by the same browser settings that are used for browser cookies.
- Web Beacons. Pages of the Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that allow us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
Information We Collect About You From Third Parties
We may receive Personal Information about you from various third parties and public sources, such as credit card issuers, financial partners, data analytics firms, public databases, social media sites and other third parties we work with.
- Google Analytics. We may use Google Analytics and web analytics services provided by Google Inc. to help us measure traffic and usage trends. Google Analytics sets a cookie to evaluate your use of the Website and compiles reports for us on activity on the Website to help us understand how visitors engage with the Website and track visitor interactions. Google Analytics collects information anonymously and without identifying individual visitors. Google stores the information collected by the cookie on servers in the United States. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google states that it will not associate your IP address with any other data held by Google. By accessing this Website, you consent to the processing of data about you by Google in the manner and for the purposes set out above. Google Analytics uses its own cookies to store information, such as what time the visit occurred, whether the visitor has been to the site before, and what site referred the visitor to the web page. To disable this type of cookie, some browsers will indicate when a cookie is being sent and allow you to decline cookies on a case-by-case basis. In addition to declining cookies, you can also install the Google Analytics Opt-out Add-on in your browser https://tools.google.com/dlpage/gaoptout?%22%20%5Ct%20%22_blank, which prevents Google Analytics from collecting information about your website visits. Learn more about the Google Analytics Opt-out Browser Add-on and other Google Analytics privacy information https://support.google.com/analytics/answer/6004245.
- Facebook Conversion Tracking Pixel. We may use Facebook Pixel. This tool allows us to understand and deliver ads and make them more relevant to you. The collected data remains anonymous, and we cannot see the personal data of any individual user. However, the collected data is saved and processed by Facebook. Facebook may be able to connect the data with your Facebook account and use the data for their own advertising purposes (in accordance with Facebook’s Data Use Policy found under: https://www.facebook.com/about/privacy/. Facebook has ultimate control of the information gathered through Facebook Pixel. You can opt out of Facebook’s use of cookies and Facebook Pixel through settings on your Facebook Account.
- Microsoft Bing UET. We may use Bing Ads' technology to collect and store data to create usage profiles using pseudonyms. This is a service of Microsoft Corporation. This service allows us to track activity on our Website of users that reached our website through advertisements by Bing Ads. If you reach our Website through such an ad, a cookie will be placed on your computer. There is a Bing UET tag integrated on our Website. This is a code used to store some non-personal information in connection with the cookie about the use of the Website. This includes, among other things, the time spent on the Website, which areas of the Website were accessed and the ad that brought users to the website. Information about your identity will not be collected. The collected information is transmitted to Microsoft servers in the United States and stored there for a maximum of 180 days. You can prevent the collection of data generated by the cookie and related to your use of the Website as well as the processing of this data by deactivating the storage of cookies. This may limit the functionality of the Website. In addition, through cross-device tracking, Microsoft may be able to track your usage behaviour across multiple of your electronic devices, enabling it to display personalized advertising on or in Microsoft websites and apps. You can disable this at http://choice.microsoft.com/en-us/opt-out. For more information about Bing's analytics services, visit the Bing Ads Web site (https://help.bingads.microsoft.com/#apex/3/en/53056/2). For more information about privacy at Microsoft and Bing, see the Microsoft Privacy Policy (https://privacy.microsoft.com/en-us/privacystatement).
Information We Create Ourselves
We may aggregate and/or anonymize Personal Information so that it will no longer be considered personal information. We do so to generate other data for our use, which we may use and disclose for any purpose. For example, we may calculate the percentage of our Website users who have a particular telephone area code.
HOW WE USE YOUR INFORMATION
We use your information, including your Personal Information, to manage our business and to maintain and develop commercial relationships with you. We will collect, use, and disclose such information only to the extent that is necessary for those and the other purposes described in this Privacy Policy.
We may use information that we collect about you or that you provide to us, including any Personal Information:
- To present the Website and its contents to you.
- To provide you with information, products, or services that you request from us.
- To fulfill the purposes for which you provided the information or that were described when it was collected, or any other purpose for which you provide it, such as facilitating the administration of your purchases, lease, warranty, maintenance program and any recall notices.
- To provide you with notices about your account.
- To carry out our obligations and enforce our rights arising from any contracts with you or to comply with legal requirements.
- To notify you about changes to the Website or any products or services we offer or provide through it.
- To improve the Website, products or services, marketing, or customer relationships and experiences.
- To allow you to participate in interactive features, social media, or similar features on the Website.
- To measure or understand the effectiveness of the advertising we serve to you and others, and to deliver relevant advertising to you.
- In any other way we may describe when you provide the information.
- For any other purpose with your consent or as otherwise permitted by law.
HOW WE SHARE YOUR INFORMATION
We will not rent or sell your information to third parties without your consent. We only share your data as specifically provided in this Privacy Policy.
Sharing With Our Partners
As described above, we necessarily share your Personal Information with SCI, the distributor of Subaru brand vehicles in Canada, in order to provide you with Subaru vehicles, products and services and to ensure your entire Subaru experience, from start to finish, is seamless. Please review SCI’s General Privacy Policy for a description of how SCI collects, uses and discloses Personal Information of Subaru customers and potential customers when you purchase or lease Subaru vehicles, purchase other Subaru products and services, and when you visit this Website and SCI’s websites and mobile apps. We may also share your Personal Information with other entities within the Subaru family for similar purposes.
We may provide your data, including your Personal Information, to our affiliated companies and brands, to third parties who provide services to you or us, such as 360 Agency Inc., who developed and operates this Website, to promotional partners, to social media companies, or to other third parties as needed to carry out our business, or comply with a legal obligation.
We may share, as the case may be and only after having obtained your explicit prior authorization, certain information about you with any financial institution involved in your acquisition of a vehicle. Please note that each financial institution sets forth its own privacy policy and we disclaim any liability relating to such policies.
Other Disclosures
In addition, we may share your data, including Personal Information, with third parties in the following limited circumstances:
- Information you expressly consent to be shared.
- When relating to anonymized information (individuals cannot be identified by it).
- To satisfy any applicable law, regulation, legal process or enforceable governmental request within or outside your country of residence when we have a good faith belief that the law requires it.
- To enforce this Privacy Policy, the Terms, or an agreement, including investigation of potential violations thereof.
- To detect, prevent, or otherwise address fraud, security or technical issues, or protect our operations or you.
- To protect our rights, property or safety as well as yours, the public, or others.
- In connection with an acquisition, merger, change in control, debt financing, reorganization, sales of assets, bankruptcy or other change of our corporate structure or status.
- As necessary in connection with the performance of requested services or solutions, or as otherwise appropriate in connection with a legitimate need.
HOW WE STORE AND SECURE YOUR INFORMATION
Information Security
We are committed to protecting the confidentiality, integrity, availability and privacy of your Personal Information. We use reasonable physical, technological and organizational security measures designed to help prevent your Personal Information from being lost, used, modified or accessed in an unauthorized way, or improperly disclosed. For example, we use encryption technology and Secure Socket Layers ("SSL") in all areas of the Website where your personal account information is required, which means the Personal Information you submit to us via the Website is encrypted by your computer and decrypted again on our side. Your personal account information and transaction history are kept behind a firewall.
Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. Any transmission you provide is at your own risk. Once we have received your information, we will apply our security practices to try to prevent unauthorized access, use and/or disclosure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the “HOW TO CONTACT US” section below.
Information Retention
We will retain your Personal Information for as long as it is needed for our business purposes including:
- To provide the products and services that you have requested.
- To communicate with you about a purchase or a request you have made to us.
- To manage your choices and rights you have exercised pursuant to this Privacy Policy.
- To enable you to maintain an account with us.
- To comply with our legal and regulatory obligations and to demonstrate compliance.
- To resolve disputes and to enforce our rights and agreements.
We may retain non-personal information that has been aggregated and anonymized for a longer period.
Once the retention period is over, we will dispose of your Personal Information in a secure manner, except as required by applicable law.
Where We Store / Transfer Information
We use facilities operated by "Amazon Web Services and located in Canada" as our information storage and processing infrastructure for the Website. By providing us with any Personal Information, you understand that your information may be transferred for processing or storage to countries outside of Canada including the United States, which may have a different data protection regime from Canada. We use contractual or other means to ensure the information is protected while in the foreign country however, in certain circumstances, courts, law enforcement agencies, government agencies, or national security authorities in those other countries may be entitled to access your Personal Information.
ACCURACY
We will make reasonable efforts to ensure that the information we have about you is accurate, complete and up to date as necessary for our uses (including information that we disclose to third parties) and to minimize the possibility that we use inaccurate information to make a decision about you.
ACCESS & CORRECTION
You have the right to request access to the information our dealership has about you and to request supporting information explaining how the personal information is used and disclosed. You also have the right to request that we correct inaccurate personal information about you. To do so, please contact us in accordance with the “How to contact us” section below.
CHALLENGING COMPLIANCE
You have the right to challenge our dealership’s compliance with applicable privacy laws and we will investigate all written complaints. To do so, please contact us in accordance with the “How to contact us” section below.
YOUR ACCOUNT INFORMATION AND PROFILE / PRIVACY SETTINGS
You can:
- Update your account at any time by logging in and changing your profile settings.
- Unsubscribe from electronic communications from us by clicking on the "unsubscribe link" provided in such communications or by sending an email to the email address in the “HOW TO CONTACT US” section below. You may not opt out of service-related communications (e.g., account verification, purchase and billing confirmations and reminders, technical and security notices).
OTHER WEBSITES AND SERVICES - THIRD PARTY PAYMENT SERVICE
This Website may contain links to other websites. They are provided for reference purposes only and may have privacy practices and policies that are different from ours. We are not responsible for, and this Privacy Policy does not address, the privacy practices of these other third parties, such as Facebook, Apple, Google, Microsoft, or any other app developers or social media platforms. If you wish to use one of these services, your personal information will be collected by such third party and will be subject to the third party’s privacy policy. Please check the privacy policies published on any third-party sites which you may access through the Website before submitting Personal Information to them. We have no control over, and are not responsible for this third party’s collection, use, and disclosure of your personal information.
HOW TO CONTACT US
If you have any questions about this Privacy Policy including about our use of service providers outside of Canada, you can contact us at:
8530 Cambie Street, Vancouver, British Columbia, V6P 6N6
{phone}
{email}
Attention: Privacy Officer
