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, Scougall Motors Ltd 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, email 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.]
Scougall Motors Ltd 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 Scougall Motors Ltd 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 Scougall Motors Ltd];
- to manage its General Motors Scougall Motors Ltd business and ensure the efficiency, reliability and security of its systems and networks;
- to meet legal and regulatory requirements and allow %DEALER_NAME % to meet contractual requirements relating to the products and services provided to customers;
- to ensure its records are accurate and to protect customers and Scougall Motors Ltd 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 Scougall Motors Ltd, 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 Scougall Motors Ltd as well as other career development resources.
Scougall Motors Ltd obtains consent from the individuals concerned for the collection, use or disclosure of personal information through various means: verbally 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 Scougall Motors Ltd 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, Scougall Motors Ltd 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 Scougall Motors Ltd 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 Scougall Motors Ltd 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 Scougall Motors Ltd 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 Scougall Motors Ltd 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, Scougall Motors Ltd 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 inquiry. 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.
Website Privacy [Scougall Motors Ltd TO DETERMINE WHAT APPLIES TO Scougall Motors Ltd SHIP ONLINE ACTIVITY]
Scougall Motors Ltd 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 Scougall Motors Ltd 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 Scougall Motors Ltd 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].
- [Behavioural Advertising. Scougall Motors Ltd 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 Behavioural 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. Scougall Motors Ltd 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 Scougall Motors Ltd itself.
Security of Personal Information
We will use reasonable security measures to protect your personal information against unauthorized access. Scougall Motors Ltd 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. Scougall Motors Ltd has developed and implemented retention procedures, and will ensure destruction of personal information in a method that prevents improper access.
Access and Correction
Scougall Motors Ltd 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
This Policy governs your interactions with our website. By continuing to use our website, you acknowledge and agree to the terms of the Policy. We may change our Policy from time to time. It is your responsibility to update yourself on changes to our Policy.
Sharing of Personal information
What information do you collect?
When you email us through our website, engage with one of our live customer service representatives through our website, or fill out a form on our website, we may collect personal information from you. Personal information is information that can be used to identify you personally. For example, we may collect your name, mailing address, phone number, email address, contact preferences, credit card information, financial information, and any other personal information that you voluntarily disclose in the course of your interactions with our website.
When you interact with our website, we may also collect non-personal information, such as your internet browser and language, internet service provider, operating system, the date and time you access our website, and your IP address. Non-personal information is not used to identify you personally unless it is combined with personal information.
How do you use my information?
We will only collect personal information and use it:
- to verify your identity;
- to verify your creditworthiness;
- to identify your preferences;
- to open and manage an account for you (for example, if we are replying to an email);
- to provide goods or services.
We will not disclose your personal information or IP address to third parties for marketing purposes.
Do I have to consent to your collection and use of my personal information?
Except in limited circumstances, we always require your consent to collect and use your personal information. Your consent may be express or implied. For example, your consent to this Policy is implied from your continued use of our website. If you have given your consent to our collection or use of your personal information and want to revoke that consent, you may do so by writing to our Privacy Officer.
Alberta privacy law, which is set out in the Personal Information Protection Act, permits us to collect and use your personal information without your consent in specific situations, including where:
- the information is already publicly available;
- there is a legal authority for the collection or use; or
- the collection or use is for the purpose of complying with an investigation or legal proceeding, creating a credit report or collecting on a debt.
How do you store and protect my personal information, and for how long?
We will store your personal information for as long as is necessary to fulfill the purposes of this Policy, and for as long as is required by law.
We take technical, contractual, administrative and physical security measures to protect your personal information in a manner that is reasonable and appropriate to the nature of the personal information you provide to us. When we destroy your personal information, we do so securely by deleting electronic files and shredding paper documents. Although we promise to do our best to protect your personal information, we cannot guarantee its security. You are responsible for taking reasonable precautions to safeguard your personal information. Always be careful when disclosing personal and non-personal information online.
Can I ask you to change an inaccuracy in my personal information?
Yes. Simply write to our Privacy Officer identifying the inaccuracy and how we can fix it. Our Privacy Officer will endeavour to respond to your request in writing within 30 days of us receiving it.
Can I ask you to tell me what personal information you have about me?
Yes. Simply write to our Privacy Officer with your request. Our Privacy Officer will endeavour to respond to your request in writing within 30 days of us receiving it. In some situations, we may not be able to provide all of the information that you request from us (for example, if it is protected by solicitor-client privilege). Please note that we reserve the right to charge a reasonable fee for complying with your request, as permitted by the Personal Information Protection Act.
Is there anything else I should know?
We are not responsible for the collection and use of information by third parties, even if you use a link on our website to access a third-party website. We encourage you to familiarize yourself with the privacy policies of any third parties with which you interact online.
What if I still have questions?
Please write or email our Privacy Officer:
Attn: Privacy Officer
Davis Auto Group Ltd.
615 W.T. Hill Blvd S