Privacy Policy

This document was last updated on Oct 1st 2024

At Canada Auto Lending we are committed to maintaining the accuracy, confidentiality and security of your personal information. This Privacy Policy describes the personal information that Canada Auto Lending collects from or about you, how we use and to whom we may disclose that information.

Privacy Policy Effective for Canada

It is Canada Auto Lending's policy to comply with the privacy legislation within each jurisdiction in which we operate. Sometimes the privacy legislation and / or an individual's right to privacy are different from one jurisdiction to another. This Privacy Policy covers only those activities that are subject to the provisions of Canada's federal and provincial privacy laws, as applicable.

This Privacy Policy has a limited scope and application. Consequently, the rights and obligations contained in this Privacy Policy may not be available to all individuals or in all jurisdictions. If you are unsure if or how this Privacy Policy applies to you, please contact our Privacy Officer for more information.

What is Personal Information?

For the purposes of this Privacy Policy, personal information is any information about an identifiable individual, other than the person's business title or business contact information when used or disclosed for the purpose of business communications.

What Personal Information do we Collect?

We may collect and maintain different types of personal information in respect of the individuals with whom we interact. This includes:

contact and identification information, such as your name, address, telephone number and e-mail address;
product and service related information concerning the products and services that we provide to, or receive from, you;
credit and financial information, such as your employment history, income sources, assets, liabilities, credit history and payment preferences;
business relationship information, including information related to your agreements, preferences, advisors and decision-makers, feed-back and information requested by or provided to you.

In addition, we may collect your personal information in connection with the financial-related services that you may seek from us, including for example, having us suggest the credit cards, loans and other financial products that, based on (i) our experience and (ii) the information you provide to us, will most likely accept you.

We may also collect market-related information, which may include personal information, concerning market trends and activities impacting our business. This information may include contract terms, financial information and other information for the purpose of market analysis and strategic planning. We may also collect information related to our media, investor and public relations activities and information related to our interactions with financial and other analysts and advisors.

From time to time, we may utilize the services of third parties in our business and may also receive personal information collected by those third parties in the course of the performance of their services for us or otherwise. Where this is the case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us.

Where permitted or required by applicable law or regulatory requirements, we may collect information about you without your knowledge or consent.

Privacy and our Website

You can visit our website without telling us who you are or revealing any information about yourself, including your e-mail address. Our web server may collect information related to your visit to our website, including the IP address and domain used to access our website, the type and version of your browser, the website you came from to access our website, the page you entered and exited at, any website page that is viewed by that IP address and what country you are from. We use this information to monitor our website's performance (such as number of visits, average time spent, page views) and for our business purposes such as working to continually upgrade our website.

In addition, we collect the personal information that you submit to our website, such as your name, address and any other contact or other information that you choose to provide by:

using the "contact us" portion of this website; or
by corresponding with a representative of Canada Auto Lending via e-mail using the hyperlinks created for that purpose.

Where you request information from us, we may use the e-mail address that you provide to send you information about offers on products and services that we believe may be of interest to you. If you have asked us to put you on an e-mail mailing list, provide you with certain information on a regular basis, or if we send you information about our offers on products and services by e-mail, you may ask us to remove you from the list at any time (using the unsubscribe instructions provided with each e-mail and on the site where you signed up).

Our Website and Cookies

When you visit the website, we place a "cookie" on the hard drive of your computer to track your visit. A cookie is a small data file that is transferred to your hard drive through your web browser that can only be read by the website that placed the cookie on your hard drive. The cookie acts as an identification card and allows our website to identify you and to record your passwords and preferences. The cookie allows us to track your visit to the website so that we can better understand your use of our website so that we can customize and tailor the website to better meet your needs.

Most web browsers are set to accept cookies. However, on most web browsers you may change this setting to have your web browser either: (1) notify you prior to a website placing a cookie on your hard drive so that you can decide whether or not to accept the cookie; or (2) automatically prevent the placing of a cookie on your hard drive. It should be noted that if cookies are not accepted, you may not be able to access a number of web pages found on the website.

What about Third Party Websites?

Our website may contain links to other websites that may be subject to less stringent privacy standards. We cannot assume any responsibility for the privacy practices, policies or actions of the third parties that operate these websites. Canada Auto Lending is not responsible for how such third parties collect, use or disclose your personal information. You should review the privacy policies of these websites before providing them with personal information.

Why Do We Collect Personal Information?

Canada Auto Lending collects personal information to enable us to manage, maintain, and develop our business and operations, including:

to establish, maintain and manage our relationship with you so that we may provide you with, or receive from you, the products and services that have been requested, including for example, to facilitate or otherwise assist you in obtaining a loan, credit card or other product or service from a third party. In connection with this, Canada Auto Lending and/or our third party business affiliates may perform a credit check on you, based on the information you have provided, to confirm your financial situation and your initial and ongoing eligibility for such products and services;
to be able to review the products and services that we provide to you so that we may understand your requirements for our products and services and so that we may work to improve our products and services;
to send you promotional and other materials that we think might be of interest to you, subject to our compliance with applicable laws;
to be able to review the products and services that we obtain from you so that we may work with you and so that you may understand our requirements for such products and services;
to be able to comply with your requests (for example, if you prefer to be contacted at a business or residential telephone number and advise us of your preference, we will use this information to contact you at that number);
to protect us against error, fraud, theft and damage to our goods and property, including verifying your identity;
to enable us to comply with applicable law or regulatory process; and
any other reasonable purpose to which you consent.

We may use your personal information to create Aggregated Information (as defined below) for the purposes of managing, maintaining, and developing our operations. Such purposes include: (i) identifying the demographics of our clients; (ii) creating and selling benchmarks, reports, summary metrics, predictive algorithms; and (iii) developing new or improving our existing products and/or services. In this Privacy Policy, "Aggregated Information" means information that: (i) arises from the compilation, combination and/or analysis of personal and other information; and (ii) is anonymized.

How Do We Use and Disclose Your Personal Information?

We may use or disclose your personal information:

for the purposes described in this Privacy Policy (including, for the purposes of Canada Auto Lending and/or our third party business affiliates performing a credit check on you to confirm your financial situation and your initial and ongoing eligibility for the products and services that you have requested); and
for any additional purposes for which we have obtained your consent to the use or disclosure of your personal information.

In addition, we may use or disclose your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.

When do we Disclose Your Personal Information?

We may share your personal information with our employees, contractors, consultants and other parties who require such information to assist us with managing our relationship with you, including: third parties that assist Canada Auto Lending in the provision of services to you and third parties whose services we use to conduct our business. Third parties may include related parties who process and store your personal information for us.

For example, our third party service providers may provide certain information technology, data processing, and advertising/marketing, and call center services to us from time to time so that we may operate our business, and as result, your personal information may be collected, used, processed, stored or disclosed in the United States of America, Canada and in Europe (including the United Kingdom and Russia), India or Asia (including China). Asa result, your personal information may be used, stored or accessed in other countries and may be subject to the laws of those countries. For example, information may be disclosed in response to valid demands or requests from government authorities, courts, or law enforcement agencies in those countries.

Where you have requested us to do so (either expressly or by your actions), we may share your personal information with persons who may consider you and/or your application for a loan, credit card or other product or service. In connection with this, Canada Auto Lending and/or our third party business affiliate to perform a credit check on you to confirm your financial situation and your initial and ongoing eligibility for the products and services you have requested.

In addition, personal information may be disclosed or transferred to another party during the course of, or completion of, a change in ownership of or the grant of a security interest in, all or a part of Canada Auto Lending or its affiliates through, for example, an asset or share sale, or some other form of business combination, merger or joint venture, provided that such party is bound by appropriate agreements or obligations and required to use or disclose your personal information in a manner consistent with the use and disclosure provisions of this Privacy Policy, unless you consent otherwise.

Further, your personal information may be disclosed:

as permitted or required by applicable law or regulatory requirements;
to comply with valid legal processes such as search warrants, subpoenas or court orders;
as above, in order to administer or service your aim to obtain credit with one or more third parties;
to protect the rights and property of Canada Auto Lending;
during emergency situations or where necessary to protect the safety of a person or group; or,
with your consent;

Your Consent is Important to Us

It is important to us that we collect, use or disclose your personal information where we have your consent to do so. Depending on the sensitivity of the personal information, your consent may be implied, deemed (using an opt-out mechanism) or express. Express consent can be given orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from your action or inaction. For example, when you enter into an agreement with us, we will assume your consent to the collection, use and disclosure of your personal information for purposes related to the performance of that agreement and for any other purposes identified to you at the relevant time.

Typically, we will seek your consent at the time that we collect your personal information. In certain circumstances, your consent may be obtained after collection but prior to our use or disclosure of your personal information. If we plan to use or disclose your personal information for a purpose not previously identified (either in this Privacy Policy or separately), we will endeavor to advise you of that purpose before such use or disclosure.

As we have described above, we may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required to do so by applicable law or regulatory requirements.

Choice/Opt-Out

You may change or withdraw your consent at any time, subject to legal or contractual obligations and reasonable notice, by contacting our Privacy Officer using the contact information set out below. All communications with respect to such withdrawal or variation of consent should be in writing and addressed to our Privacy Officer.

In certain circumstances, the withdrawal of consent may render us unable to continue to provide products or services where the collection, use or disclosure of your personal information is necessary to provide the product or service.

We assume that, unless you advise us otherwise, you have consented to the collection, use and disclosure of your personal information as explained in this Privacy Policy.

How is Your Personal Information Protected?

Canada Auto Lending endeavors to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to prevent your personal information from loss and unauthorized access, copying, use, modification or disclosure.

The security of your personal information is important to us, please advise our Privacy Officer immediately of any incident involving the loss of or unauthorized access to or disclosure of personal information that is in our custody or control.

Updating Your Personal Information

It is important that the information contained in our records is both accurate and current. If your personal information happens to change during the course of our relationship, please inform our Customer Care department of this change. If our Customer Care department is unable to help you, please contact our Privacy Officer using the contact information below.

In some circumstances we may not agree with your request to change your personal information and will instead append an alternative text to the record in question.

Access to Your Personal Information

You can ask to see your personal information. If you want to review, verify or correct your personal information, please contact our Customer Care department, and if our Customer Care department is unable to help you, please contact our Privacy Officer using the contact information below. Please note that any such communication must be in writing.

When requesting access to your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information that we hold about you. We may charge you a fee to access your personal information; however, we will advise you of any fee in advance. If you require assistance in preparing your request, please contact our Customer Care department. If our Customer Care department is unable to help you, please contact our Privacy Officer using the contact information below

Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices.

In the event that we cannot provide you with access to your personal information, we will endeavor to inform you of the reasons why, subject to any legal or regulatory restrictions.

Inquiries or Concerns?

If you have any questions about this Privacy Policy or concerns about how we manage your personal information, please contact our Customer Care department by telephone, in writing or by e-mail. We will endeavor to answer your questions and advise you of any steps taken to address the issues raised by you. If our Customer Care department is unable to help you, please contact our Privacy Officer using the contact information below. If you remain dissatisfied with our response, you may be entitled to make a written submission to the Privacy Commissioner in your jurisdiction.

Privacy Officer

We have appointed a Privacy Officer to oversee compliance with this Privacy Policy. The contact information for our Privacy Officer is as follows:

By Email to:

support@canadaautolending.com

Revisions to this Privacy Policy

Canada Auto Lending from time to time, may make changes to this Privacy Policy to reflect changes in its legal or regulatory obligations or in the manner in which we deal with your personal information. We will post any revised version of this Privacy Policy on our website (www.canadaautolending.com) and we encourage you to refer back to it on a regular basis.

Interpretation of this Privacy Policy

Any interpretation associated with this Privacy Policy will be made by our Privacy Officer. This Privacy Policy includes examples but is not intended to be restricted in its application to such examples, therefore where the word 'including' is used, it shall mean 'including without limitation'.

This Privacy Policy does not create or confer upon any individual any rights, or impose upon Canada Auto Lending any obligations outside of, or in addition to, any obligations imposed by Canada's federal and provincial privacy laws, as applicable. Should there be, in a specific case, any inconsistency between this Privacy Policy and Canada's federal and provincial privacy laws, as applicable, this Privacy Policy shall be interpreted, in respect of that case, to give effect to, and comply with, such privacy laws.