Personal information protection policy of automobile en direct

The company automobile en direct.com inc. ("Automobile En Direct", "we", "us" or "our"), owner and operator of the website accessible at automobileendirect.com (the "Site"), is concerned about your privacy and the protection of your Personal Information (as defined hereinafter) and wishes to provide its users with a secure environment that respects their privacy. That is why we are committed to ensuring the accuracy, security and confidentiality of the Personal Information collected about you by rigorously applying this Personal Information Protection Policy (the "Policy") in accordance with applicable laws.

The purpose of this Policy is to inform you about how Automobile En Direct collects, uses, discloses, retains, protects and destroy your Personal Information.

This Policy does not apply to third-party websites and software that can be accessed through the Site.

In order to provide you with the best possible services, we must have access to certain Personal Information about you. We make sure that our employees manage this information with all the necessary discretion and rigor, and this, in accordance with the legal and regulatory requirements in force.

We define "Personal Information" as any information that relates to an individual or that, taken separately or in combination with other data, allows such individual to be identified, including, but not limited to, your names, address, email, date of birth or sex.

We collect only the Personal Information necessary to establish, manage and maintain our relationship with you in order to provide you with the best possible service.

In the course of our interactions with you, whether you are dealing with our staff, we need to collect certain Personal Information about you. The Personal Information we collect is necessary in order to provide you with the services you have requested, including, but is not limited to:

• Your contact information such as a name, address, email or phone number to identify you and correspond with you;
• Marketing information and communication preferences such as comments, survey responses, etc.;
• Information related to the use of our website including technical information about visits or any other information collected through Cookies (as defined hereinafter), Web Beacons (as defined hereinafter) or other similar tools;
• As part of a job application, recruitment-related information such as resumes, information about your professional or academic background, or any otherinformation relevant to a potential recruitment; and
• Any other Personal Information provided.

In addition to this information, we also collect the following anonymous data in connection with your use of our Site:

• The number of visits;
• The conversion rate;
• The average length of your visit;
• The actions performed on our Site;
• The pages consulted during your visit;
• The type of device used during your visit;
• The Web browser used during your visit;
• The IP address used during your visit;
• The origin of visitors, i.e., the Web page you visited before being redirected to our Site; and
• The advertising campaign that brought you to our Site.

We do not seek to collect information about minors. If you have concerns regarding the protection of your child's Personal Information in connection with the Site, or if you believe that your child may have disclosed Personal Information, please contact us using the contact information provided in the "Questions, comments, complaints” Section below.

Automobile En Direct collects your Personal Information primarily from you, but also from third parties or through the use of Cookies (as defined hereinafter) or Web Beacons (as defined hereinafter).

1. From you

You provide us with Personal Information directly when you use our services, when you communicate with us or when you click on an advertisement that we have placed on a third-party website (e.g. Google, Facebook, etc.).

2. From third parties

We may also collect Personal Information from third parties, or from publicly available records as permitted by law or where we have obtained consent.

3. From the chat tool

In connection with the use of the chat tool, Automobile En Direct offers you online services through an agent who may, if necessary, request and collect information about you. This information establishes your identity and also allows you to benefit from the services that are available through this tool and that are best suited to your needs.

4. Cookies

Cookies are small data files that are commonly stored on your device when using websites and online services (the “Cookies”). They are used for the efficient operation of websites and can provide information and help customize services. Automobile En Direct collects the Personal Information provided by Cookies.

5. Web Beacons

Web beacons are tiny images that we may place on our Web pages or in our emails. They can be used, for example, to anonymously obtain the number of times a particular page has been visited by a user (the “Web Beacons”). As their name implies, Web Beacons are invisible and any part of our Site, including the advertising messages displayed therein, may contain Web Beacons. Unlike Cookies, Web Beacons are not placed on your computer.

6. Use for research and development purposes

Information obtained through the use of Cookies or Web Beacons may also be used for research and development purposes and to improve your experience within our Site. In such a case, the information is anonymized and used primarily for statistical purposes. However, we would like to reassure you that no data that could identify you will be used. As mentioned above, this is anonymized data that will be used for statistical and research purposes.

As mentioned in the previous section, we may use different tools to improve your Web experience, better understand our customers' behaviour, and this, especially in relation to our marketing strategies. The following section is intended to provide you with more information about our use of these tools.

Cookies and Web Beacons

By using Cookies and Web Beacons, we are able to provide you with advertising that better meets your needs, as it is targeted to your interests. When you visit our Site, Cookies and Web Beacons tell us, among other things, which pages are of interest to you and, therefore, we may subsequently display advertising that is relevant to your interests.

These technologies do not contain any personally identifiable information. They may,however, contain a unique identifier required for retargeting. When you click on one ofthese ads, we may also track the response rate of the campaign.

Automobile En Direct uses different types of Cookies:

• Performance and Functionality Cookies: These cookies are not essential to the providing of our services. They make it easier to personalize and enhance the user experience. For example, they can remember your preferences, so you don’t have to re-enter information more than once or remember your credentials, so you don’t have to re-enter them each time you use the Site. They allow us to understand your behaviour in order to improve our services and our Site.
• Cookies for advertising purposes: These Cookies are not essential to the providing of our services. They use information about your visit to the Site, such as pages viewed or ad response, to help provide the best user experience for your situation
• Security Cookies: These Cookies help protect your accounts from unauthorized users. They help maintain session integrity and provide enhanced security, ensuring that unauthorized attempts to access your account are blocked.

Please note that the use of Cookies only identifies you as a user and does not recognize you by name or address.

Disabling Cookies

It is possible to prevent the Site’s customization features by disabling Cookies on your browser. You can do this by changing the settings on your browser or mobile device.

However, if you choose to disable Cookies, certain pages or sections of our Site may not display properly or certain features may not be available.

Do other websites have access to Cookies when you browse our Site?

From time to time, we may use third-party service providers

Indeed, when you access our Site, directly or through an advertisement that redirects you to it, a Cookie file is automatically created on your computer or mobile device. At that time, a web analytics tool (for example, Google Analytics and Amplitude) and possibly external ad servers have access to this Cookie, which allows us to provide you with a better experience on our Site or, in some cases, to track your activity to promote some of our products. Although a code in the Cookie file identifies you as a user, it does not recognize you by name or address.

Our service providers may also need to collect your IP address or mobile device identifier, if applicable, when you visit a site. This information may be transmitted to and stored on servers located in Canada or elsewhere, such as the United States. Automobile En Direct does not combine any information collected by these third parties with information we hold about you. Please be aware, however, that certain suppliers may be required to disclose the data collected to third parties if required by law or if they wish to entrust the processing of certain data to third parties. No information that would allow these suppliers to identify you is transmitted to them.

Please note that third-party service providers have their own Cookies and privacy policies.

Use of Google Analytics

Automobile En Direct uses Google Analytics, which is provided by Google Inc. (Google) in order to analyze the browsing behaviours of visitors to the Site, which are tools for analyzing website traffic and use.

The information collected by Google Analytics is used to analyze the use of our Site and to produce statistical reports on visitor activity. You can obtain more information about Google Analytics here.

Targeted Advertising

Automobile En Direct also works with third-party advertising companies, such as Facebook, that collect and use information about your visits to our Site in order to present you with advertising that may be of interest to you. Automobile En Direct does not share any information that would allow advertising companies to identify you.

Please note that our advertising partners and other third parties may also set Cookies or Web Beacons when you click on their advertisements or links to their websites or services on our Site. This Policy does not apply to third-party websites or third-party advertising providers.

You can disable Google Analytics while browsing by selecting the appropriate settings for your browser or computer tool, as well as ad settings. It is possible to refuse to share your information with these third parties by installing an add-on module and thus refuse to receive ads targeted by interests.

Automobile En Direct also uses Facebook's personalized audience feature to target advertising related to the interests of its current and potential customers. To unsubscribe from Facebook's personalized audience feature, use this procedure.

Please note that even if you choose not to receive targeted advertising based on your interests, it will still be possible to see Automobile En Direct ads. In this case, these ads will simply not be adapted to your real needs and could be displayed more frequently.

Social Media Features

Our services include social media features such as the Facebook share button or interactive mini-programs that run on our Site. If you use these features, they collect your IP address, the page you visit on our Site and create a Cookie to enable these features to function properly. These features may be hosted by a third party or directly on our Site. Your interaction with these features is governed by the privacy policy of the company offering the feature and not by this Policy.

Link to websites

It is important to understand that this Policy does not apply to other third party websites that may be accessed from links on our Site. We are not responsible for these third-party websites, their content or access. Consequently, any Personal Information you transmit through these websites is subject to the privacy policy of the latter. It is your responsibility to review the privacy policy of each site to ensure the protection of your Personal Information.

Automobile En Direct collects, uses and discloses Personal Information for the purposes identified at the time of collection or as permitted or required by law. This includes but is not limited to the following purposes:

• Establish and manage our relationship with you;
• Provide services including the purchase and leasing of motor vehicles;
• To facilitate the use of our Site, ensure its relevance and monitor its use;
• Respond to your requests for information;
• Develop and improve the Site based on your research, usage, and the options you choose;
• To allow business development and marketing in order to inform our current and future customers about our new offers with the prior agreement of the person concerned;
• Conduct development and research to ensure that we maintain the highest standard of security and understand our customers' requirements in order to improve our offering;
• Communicate with you information regarding changes and improvements to the services offered and the Site;
• Recruit staff, process applications and evaluate the candidate's profile in relation to the requirements of the position;
• As permitted or required, for any applicable legal or regulatory requirements or provisions; or
• Any other purpose to which you have consented.

Except as already provided by applicable privacy legislation, Automobile En Direct will obtain your consent before using your Personal Information for purposes not previously identified.

Your consent to the collection, use and disclosure of your Personal Information is required, unless the law does not require it and in which case we may collect, use or disclose Personal Information without formal notice or without your consent.

By accessing the site and using the services of automobile en direct, you expressly provide automobile en direct with your voluntary consent to the collection, use and disclosure of your personal information in accordance with the provisions of this policy.

You declare that you are aware of why Automobile En Direct collects, processes and uses this Personal Information, how it will be collected and how your privacy will be protected.

You may, at any time, and subject to reasonable notice and applicable legal or contractual restrictions, withdraw your consent to the use of Personal Information already collected by contacting our Privacy Officer. Your refusal to disclose Personal Information or the withdrawal of your consent may prevent us from providing or continuing to provide you with some of our services, as Personal Information may be necessary for the proper management or administration of your files or the provision of services related to your file. In such circumstances, you should be aware that we may be forced to close your file or stop providing you with a product or service.

Automobile En Direct may also ask for your consent to use your Personal Information for secondary purposes, such as market research or to populate its databases. As noted above, we will seek your consent in this regard. In addition, your consent for secondary use may be withdrawn at any time, without affecting the provision of our services to you.

In order to provide our services to you, we may share the Personal Information we collect with certain third parties. Please note that these third parties may be located in Canada or in other jurisdictions or countries. In the course of its activities, Automobile En Direct may disclose your information to third parties, including in particular:

• Third-party service providers including, in particular, services related to the Site (hosting, security, maintenance, analysis, fraud detection, marketing, etc.). The Personal Information provided is then limited to only the Personal Information necessary for the performance of their services and these suppliers are obliged to maintain the confidentiality of this Personal Information; or
• Governmental public authorities and law enforcement agencies where required by applicable laws or where necessary for the provision of our services.

With the exception of the above, Automobile En Direct will not disclose your Personal Information to third parties without your prior consent. In addition, prior to disclosing your Personal Information to third parties, such third parties must agree to abide by strict contractual conditions requiring them (i) to maintain the confidentiality of the Personal Information disclosed to them; (ii) to retain and use such Personal Information only for the purposes set out herein; and (iii) to destroy such Personal Information once it has been used for the authorized purposes.

Please note that we may also share your Personal Information when required by law, to enforce compliance or to protect the property or safety of our rights or those of others. For example, we may disclose Personal Information to legal or regulatory authorities in the event we suspect criminal activity, to detect and prevent fraud, or to comply with legal or regulatory requirements of government authorities, regulatory agencies or other self-regulatory organizations. We may also need to disclose Personal Information to comply with a legal obligation (for example, a court order) or to protect our assets (for example, to collect overdue accounts, for example).

We will retain your Personal Information only for as long as necessary to fulfill the purpose for which it was collected and to meet legal retention requirements, and for as long as necessary to protect our legitimate business interests

Procedures for the retention of your Personal Information are in place and we will dispose of Personal Information that is no longer required by Automobile En Direct for the identified purposes.

If you wish to obtain additional information, we invite you to contact us using the contact information listed in the "Questions, Comments, Complaints" section of this Policy.

The security and confidentiality of your Personal Information is important to us. We strive to apply the necessary and appropriate security measures to ensure the confidentiality of the Personal Information in our possession. To do so, we follow generally accepted industry standards. The Personal Information that we hold is therefore accessible only to persons who are qualified to have access to it and who consult it only when necessary in the performance of their duties.

Appropriate physical, technical and/or administrative protection and security measures have been put in place and are maintained in order to avoid:

• Any accidental or unlawful destruction;
• Any accidental loss;
• Any unauthorized disclosure;
• Unauthorized modification;
• Unauthorized access; and
• Any illegal processing.

Unfortunately, we cannot absolutely guarantee the security of Personal Information collected or transmitted when accessing the Site or your use of the services provided on the Site.

You therefore understand and agree that (i) there are limits to the security and confidentiality of the Personal Information collected that are beyond the control of Automobile En Direct; (ii) the security, integrity and confidentiality of all Personal Information and data exchanged between you and Automobile En Direct through the Site cannot be guaranteed; and (iii) such Personal Information may be viewed or altered by a third party at the time of transfer. For these reasons, Automobile En Direct cannot be held responsible for any loss, interception or alteration of Personal Information.

You may request access to your Personal Information or information about the existence of such information or about the manner in which we collect, use, maintain, disclose or destroy your Personal Information. You may also request that information held by Automobile En Direct be corrected if it is found to be inaccurate, equivocal or incomplete.

You may submit a written request to this effect by writing to the Privacy Officer at the address indicated in the "Questions, Comments, Complaints" Section below.

When we receive a request for access, rectification or deletion, we strive to respond within a reasonable period of time following receipt of said requests.

In certain situations, it may not be possible for Automobile En Direct to disclose all the Personal Information it holds about you. Exceptions to the access requirements are limited and specific. The reasons for denying access are provided upon request.

These exceptions include information that is prohibitively costly to transmit, information that contains details about other individuals, legal, security or commercial reasons that prevent the transmission of the information, and information that is protected by solicitor-client or litigation privilege.

Reasonable fees may be charged for the transcription, reproduction or transmission of Personal Information.

Automobile En Direct may, at its discretion, update, revise, modify or supplement this Policy from time to time. If a change is made to the Policy, you will be notified when you log in and/or we will send you a link to the new version of the Policy. The Policy and any related agreements, if any, will be posted on the Site. Automobile En Direct requires its users to review the amended Policy before continuing to use the Site.

Continued use of the Site provided by Automobile En Direct after the effective date of the amended Policy shall constitute consent to the amended Policy.

To contact us, ask questions about this Policy, send us your comments, submit a request for access or correction, exercise any applicable right, file a complaint or obtain information about our practices or policies, we invite you to contact our Privacy Officer at the following address:

Automobile en direct.com inc
Attention of: Privacy Officer
Email: [email protected]
360, route 132,
Saint-Constant (Québec) J5A 1M3

Automobile En Direct wants you to know that we are committed to responding promptly and accurately to all of your questions and concerns about the privacy and security of your Personal Information and our privacy policies and procedures.

In the event of a complaint from you regarding the exercise of your rights set out in this Policy, your file will be handled by the office of the Privacy Officer at Automobile En Direct, who will inform you of the procedure to follow. Each complaint will be investigated. If the complaint is justified, the particular situation will be corrected and you will be informed of the outcome.