Spring Financial Privacy Policy Last Updated
August 19, 2019
Your privacy is important to Canada Drives Ltd., and its corporate affiliates, including Canada Drives Auto Finance Ltd., Spring Financial Inc., Spring Auto Finance Ltd., Spring Mortgage Group Inc., 1025479 B.C. Ltd., and 1195407 B.C. Ltd. (collectively, “Canada Drives Group” and each a “Canada Drives Company”). This Privacy Policy explains how Canada Drives Group collects, uses, discloses and retains personal information, including information collected by Canada Drives Group through websites and telephone calls and when providing products or services.
By providing a Canada Drives Company with your personal information, you consent to the collection, use, disclosure and retention of that information by the Canada Drives Company and other members of the Canada Drives Group in accordance with this Privacy Policy and as otherwise permitted by applicable law. You may withdraw your consent at any time, subject to legal or contractual restrictions and on reasonable notice to Canada Drives Group, but then you might not be able to proceed with your intended interactions or transactions with Canada Drives Group or otherwise receive the full benefit of Canada Drives Group’s products and services.
In this Privacy Policy, “personal information” means information about an identifiable individual, such as an individual’s name and email address, but does not include (to the extent permitted by law) information that is publicly available in a telephone directory or that is business contact information that enables an individual to be contacted at a place of business.
(a) Information You Provide
You may be asked to voluntarily
give your personal information to a
Canada Drives Company when you
interact, orally, in writing or by
electronic transmission, with the
Canada Drives Company, including
when you apply for an account or
membership, subscribe to a
newsletter, register to receive
information, apply or register for or
order a product or service offered
by a Canada Drives Company or
use a product or service provided
by a Canada Drives Company. In
those circumstances, you can
choose not to provide certain
requested personal information,
but then you might not be able to
proceed with your intended
interaction or transaction with the
Canada Drives Company or
otherwise receive the full benefit of
the desired product or service.
Telephone calls between you and
the Canada Drives Company will be
recorded to ensure accuracy and
quality assurance, and may be
disclosed to third parties to verify
the Canada Drives Company is
compliant with its contractual
obligations to third parties. You can
choose not to have the telephone
call recorded, and communicate by
writing or electronic transmission.
(b) Automated Collection
A Canada Drives Company may
automatically collect certain
information regarding your use of
the Canada Drives Company’s
website or online service, such as
the dates and times that you
access the website or online
service, the browsers, operating
systems, software and devices that
you use to access the website or
online service and details of your
use of the website or online
service.
A Canada Drives Company’s
websites, online services, email
messages and advertisements may
use technologies (e.g. cookies, web
beacons, tokens, pixels or tags) to
collect information that assists the
Canada Drives Company to
improve its products, services,
customer communications and
advertising and to prevent fraud. A
Canada Drives Company may use
information that it collects through
technological means to recognize
you as a user of the Canada Drives
Company’s websites or online
services, to facilitate and improve
your use of the Canada Drives
Company’s websites or online
services, to confirm that messages
have been delivered to and opened
by you and to provide you with
targeted advertisements. You may
choose to decline or disable
cookies if your web browser or
device permits, but doing so may
affect your ability to access or use
certain features of a website or
online service. More information
about cookies used for interest-
based advertising is set out in
section 4(c) below.
Much of the information that is
automatically collected by
technological means is non-
personal information (because the
information does not identify you),
and Canada Drives Group will deal
with that non-personal information
as explained below in this Privacy
Policy unless applicable law
requires otherwise.
(c) Credit Reports
When you apply or register for,
order or use certain products or
services from a Canada Drives
Company (e.g. a referral to a car
dealer for a financed car purchase),
the Canada Drives Company may
obtain your credit score and
related information from a credit
reporting agency to process or
fulfill the transaction. The Canada
Drives Company may continue to
periodically obtain your credit
score and related information from
a credit reporting agency to update
your confidential profile for use by
Canada Drives Group as set out in
this Privacy Policy. Upon your
request we will inform you if we
have ordered such a report or
reports, and will give you the name
and address of the credit reporting
agency that furnished the report or
reports.
You also acknowledge and agree
that any dealers or other persons
or organizations to which we have
disclosed your personal
information in accordance with this
Privacy Policy, may request a credit
report for any legitimate purpose
associated with your application
[for credit, extending credit,
modifying the terms of your credit
agreement, or collection on your
account.]
(d) Information Regarding Referred Transactions
If a Canada Drives Company refers
you to an independent business
(e.g. a car dealer, lender or credit
card company) for a proposed
transaction (e.g. a car purchase,
loan or credit card), then the
Canada Drives Company may
collect from that independent
business information regarding the
transaction to update your
confidential profile for use by
Canada Drives Group as set out in
this Privacy Policy.
(a) General
Each Canada Drives Company
uses your personal information
collected by the Canada Drives
Company for purposes relating
to or arising from your
relationship and transactions
with the Canada Drives Company
and as otherwise set out in this
Privacy Policy or permitted by
applicable law, including:
• to administer your relationship
with Canada Drives Group,
including to create and manage
your account or membership
with Canada Drives Group and to
contact and correspond with you
regarding those matters;
• to facilitate your interactions and
transactions with Canada Drives
Group, including to process your
applications, requests, orders
and payments;
• to provide products and services
to you;
• to process and respond to your
inquiries, requests and other
communications;
to provide you with information
(including by email and other
electronic messages) regarding
Canada Drives Group and its
products and services and
related products and services
offered by other businesses, to
the extent permitted by
applicable law;
• to administer and facilitate your
participation in contests and
promotions related to Canada
Drives Group;
• to maintain, protect and improve
Canada Drives Group’s products
and services and to develop new
products and services;
• to protect and enforce Canada
Drives Group’s legal rights,
interests and remedies and to
protect the business, operations
and customers of Canada Drives
Group or other persons; and
• to assist other Canada Drives
Companies to collect, use,
disclose and retain your personal
information in accordance with
this Privacy Policy.
(b) Canada Drives Group
A Canada Drives Company may
share your personal information
with the entire Canada Drives
Group, and the Canada Drives
Group may develop, maintain
and share a confidential profile
for you for use by each Canada
Drives Company to provide
information, products and
services to you, to facilitate your
dealings with each Canada Drives
Company and as otherwise set
out in this Privacy Policy.
(c) Interest-Based Advertising
The Canada Drives Group may
use interest-based advertising
services (sometimes called
“remarketing” or “retargeting”)
provided by third party vendors
(such as Google and Facebook) to
display advertisements on third
party websites and social media
sites visited by users of a Canada
Drives Group website.
Advertising vendors (such as
Google and Facebook) use
cookies, pixels or tokens – unique
identifiers of a web browser on a
specific computer that are
installed on the computer when
it accesses Canada Drives Group
websites – to display ads based
on the computer’s past access to
Canada Drives Group websites.
You can opt-out of Google’s use
of cookies by visiting Google’s
Ads Settings. You can also opt
out of a remarketing vendor’s
use of cookies by visiting the
Network Advertising Initiative’s
consumer opt-out page.
(a) General
Each Canada Drives Company
discloses your personal
information for purposes relating
to or arising from your
relationship and transactions with
the Canada Drives Company and
as otherwise set out in this
Privacy Policy or permitted by
applicable law.
(b) Specific Consents
A Canada Drives Company may
disclose your personal
information in accordance with
express or implied consents that
you give during your interactions
and transactions with the Canada
Drives Company.
(c) Referred Transactions
If a Canada Drives Company
refers you to an independent
business (e.g. a car dealer, lender
or credit card company) for a
proposed transaction (e.g. a car
purchase, loan or credit card
application), then the Canada
Drives Company may disclose
your personal information
(including your credit score and
related information) to the
independent business to facilitate
the proposed transaction. Canada
Drives Group has no control over,
or responsibility or liability for,
the use, disclosure or retention of
your personal information by the
independent business, and the
use, disclosure and retention of
the disclosed information by the
independent business is not
subject to this Privacy Policy.
(d) Suppliers and Service
Providers
A Canada Drives Company may
disclose your personal
information to its suppliers and
service providers (including fraud
prevention services and payment
processors) to assist the Canada
Drives Company in the provision
of information, products and
services to you, to provide
services to the Canada Drives
Company, to assist the Canada
Drives Company to use your
personal information as set out in
this Privacy Policy and as
otherwise permitted by applicable
law.
(e) Law Enforcement/Legal
Disclosures
A Canada Drives Company may
disclose your personal
information as required or
authorized by applicable law,
including to comply with a
subpoena, warrant or court or
arbitral order or litigation
disclosure obligation. A Canada
Drives Company may disclose
your personal information to law
enforcement agencies or other
independent organizations if the
Canada Drives Company
reasonably believes the
disclosure is necessary or
appropriate in connection with
national security, law
enforcement or other issues of
public importance, or if the
Canada Drives Company
reasonably believes the
disclosure is necessary or
appropriate to protect and
enforce the Canada Drives
Company’s legal rights, interests
and remedies or to protect the
rights, interests, business,
operations or customers of the
Canada Drives Company or other
persons (including to detect and
prevent fraud and other illegal
activities, enforce any of the
terms of use, terms of service or
other agreements that govern
access to or use of any of the
Canada Drives Company’s
products or services). A Canada
Drives Company has no control
over, or responsibility or liability
for, the use, disclosure or
retention of your personal
information by the agencies,
independent organizations or
other persons to whom the
Canada Drives Company discloses
the information in the foregoing
circumstances, and the use,
disclosure and retention of the
disclosed information by those
agencies, independent
organizations or other persons is
not subject to this Privacy Policy.
(f) Business Transactions
A Canada Drives Company may
disclose your personal
information in connection with a
proposed or actual business
transaction in which the Canada
Drives Company is involved (such
as a corporate amalgamation,
reorganization, merger or
acquisition, or the sale or transfer
of some or all of the Canada
Drives Company’s business or
assets), but the Canada Drives
Company will require the
information recipient agree to
protect the privacy of your
personal information in a manner
that is consistent with this Privacy
Policy and applicable law.
Canada Drives Group and its service providers may process, store and use your personal information at facilities in various countries, including Canada, the United States of America and one or more countries in Europe or Asia. The personal information protection laws of those other countries might be different from the laws of the jurisdiction in which you reside, and might permit courts, government, law enforcement agencies, regulatory agencies and security authorities to access your personal information without notice. By providing your personal information to a Canada Drives Company, you consent to the transfer of the personal information to facilities located in other countries and the processing and storage of the personal information at those facilities.
Canada Drives Group retains your personal information for the period reasonably necessary for the purposes set out or referenced in this Privacy Policy and to comply with Canada Drives Group’s legal obligations or enforce or protect Canada Drives Group’s legal rights, or a longer period required or permitted by applicable law. Canada Drives Group will delete or dispose of your personal information when Canada Drives Group is no longer reasonably required to retain the information for the purposes set out or referenced in this Privacy Policy.
Canada Drives Group uses reasonable safeguards – including administrative, physical and technical security and safeguarding measures – appropriate to the sensitivity of the personal information in Canada Drives Group’s possession or under Canada Drives Group’s control to help protect the information from unauthorized access, collection, use, disclosure, disposal or similar risks. Nevertheless, security risks cannot be eliminated and Canada Drives Group cannot guarantee that your personal information will not be used, disclosed or deleted in ways not otherwise described in this Privacy Policy.
Canada Drives Group will rely on
you to ensure that your personal
information that you provide to
Canada Drives Group is as
accurate, complete and up to date
as necessary for the purposes for
which Canada Drives Group uses
the personal information. You will
promptly notify Canada Drives
Group of any changes to your
personal information using the
procedures made available for that
purpose by Canada Drives Group or
by contacting Canada Drives
Group’s customer service.
You may reasonably request access
to your personal information
collected by Canada Drives Group
and information about Canada
Drives Group’s use, disclosure and
retention of that personal
information by submitting a written
request to Canada Drives Group’s
Chief Privacy Officer using the
contact information noted below.
Subject to applicable exceptions
and limitations prescribed by
applicable law, you will be given
reasonable access to your personal
information and you will be entitled
to verify the accuracy and
completeness of your personal
information and to have the
information revised as appropriate.
You may be required to pay a
reasonable fee for access to your
personal information. Canada
Drives Group may decline to
process a request that is
unreasonably repetitive, frivolous,
vexatious or impracticable, that
infringes or jeopardizes the privacy
of other persons, or for other
reasons permitted by applicable
law.
Canada Drives Group creates and collects non-personal information (information that is not about an identifiable individual), including personal information that has been aggregated or otherwise depersonalized so that the information no longer relates to an identifiable individual. Canada Drives Group may use, disclose, transfer and retain non-personal information for any purpose and in any manner whatsoever. If non- personal information is combined with personal information, then Canada Drives Group will treat the combined non-personal information as personal information for the purposes of this Privacy Policy for as long as the non-personal information is combined.
Canada Drives Group’s websites and correspondence (including emails and messages) may include advertisements for products and services (e.g. car sales, personal loans and credit cards) offered by independent businesses (that may have a financial relationship with a Canada Drives Company) or links to websites operated by independent businesses (e.g. car dealers, lenders and credit card providers). Canada Drives Group has no responsibility or liability for, or control over, those other websites, online services or businesses, their products or services, or their collection, use, disclosure or retention of your personal information. This Privacy Policy does not apply to the collection, use, disclosure and retention of your personal information by those websites, online services and independent businesses. If you have questions about how those websites, online services or independent businesses collect, use, disclose or retain personal information, please contact the owner or operator of the website, service or business.
(a) Disclaimers, Liability
Exclusions/Limitations and
Disputes:
The agreements
(including any subscription
agreement, membership agreement
or terms of service or use) that you
accept when you apply, register for,
order or use Canada Drives Group’s
products or services contain
important provisions, including
provisions disclaiming, limiting or
excluding the liability of Canada
Drives Group and other persons
(including service providers) and
provisions determining the
applicable law and jurisdiction for
the resolution of disputes. To the
extent permitted by applicable law,
each of those provisions applies to
any dispute that may arise in
relation to this Privacy Policy or
Canada Drives Group’s collection,
use, disclosure and retention of
your personal information, and are
of the same force and effect as if
they had been reproduced directly
in this Privacy Policy. Nothing in this
Privacy Policy amends any of those
other agreements.
(b) Changes to this Policy:
A
Canada Drives Company may
change this Privacy Policy from time
to time by posting a new version of
this Privacy Policy on the Canada
Drives Company’s website. A
Canada Drives Company’s
collection, use, disclosure and
retention of your personal
information will be governed by the
version of this Privacy Policy in
effect at that time. Your continued
dealings with a Canada Drives
Company after any change to this
Privacy Policy will signify your
consent to the collection, use,
disclosure and retention of your
personal information as set out in
the changed Privacy Policy.
Accordingly, you should check the
“Last Updated” date of this Privacy
Policy (at the top of this Privacy
Policy) and review any changes
since the last version.
(c) English Language:
You and
Canada Drives Group have each
expressly requested and required
that this Privacy Policy and all other
related documents be drawn up in
the English language. Les parties
conviennent et exigent
expressement que cette Politique
de Confidentialité et tous les
documents qui s’y rapportent soient
rédigés en anglais.
(d) Contacting Canada Drives
Group’s Chief Privacy Officer:
If
you have any comments or
questions about this Privacy Policy
or how Canada Drives Group deals
with your personal information,
please contact Canada Drives
Group’s Chief Privacy Officer by mail
or email at: Canada Drives Group –
Chief Privacy Officer, Suite 600, Two
Bentall Centre, 555 Burrard Street,
Vancouver, British Columbia,
Canada, V7X 1M8; email:
[email protected]