This Privacy Policy explains how HAH Auto Group collects, uses, discloses and retains personal information, including information collected by HAH Auto Group through websites and telephone calls and when providing products or services.

1. Your Consent

By providing a HAH Auto Company with your personal information, you consent to the collection, use, disclosure and retention of that information by the HAH Auto Company and other members of the HAH Auto 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 HAH Auto Group, but then you might not be able to proceed with your intended interactions or transactions with HAH Auto Group or otherwise receive the full benefit of HAH Auto Group’s products and services.

2. Personal Information

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.

3. Information That HAH Auto Group Collects

(a) Information You Provide
You may be asked to voluntarily give your personal information to a HAH Auto Company when you interact, orally, in writing or by electronic transmission, with the HAH Auto 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 HAH Auto Company or use a product or service provided by a HAH Auto 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 HAH Auto Company or otherwise receive the full benefit of the desired product or service. Telephone calls between you and the HAH Auto Company will be recorded to ensure accuracy and quality assurance, and may be disclosed to third parties to verify the HAH Auto 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 HAH Auto Company may automatically collect certain information regarding your use of the HAH Auto 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 HAH Auto 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 HAH Auto Company to improve its products, services, customer communications and advertising and to prevent fraud. A HAH Auto Company may use information that it collects through technological means to recognize you as a user of the HAH Auto Company’s websites or online services, to facilitate and improve your use of the HAH Auto 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 HAH Auto 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 HAH Auto Company (e.g. purchase a vehicle, apply for financing, or apply for pre-approval for financing), the HAH Auto Company may obtain, and continue to periodically obtain, your credit score and related information from a credit reporting agency to process or fulfill the transaction, and to update your confidential profile for use by HAH Auto Group for purposes 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, collection on your account, or similar services or products.

(d) Bank Information
When you use the bank account verification system (“Bank Verification System”) from within a HAH Auto Company’s website, the HAH Auto Company may, in accordance with this Privacy Policy and the HAH Auto Group General Terms of Service, retrieve your bank account information, including your transaction history (but not your bank account log-in credentials) for purposes as set out in this Privacy Policy. The HAH Auto Company may use the Bank Verification System to periodically obtain your updated bank account information in order to update your confidential profile for use by HAH Auto Group for purposes as set out in this Privacy Policy.

For clarity, you acknowledge and agree that a HAH Auto Company may periodically retrieve your bank account information and disclose the bank account information to independent businesses, including HAH Auto Company’s suppliers or service providers, for purposes as set out in this Privacy Policy.

(e) Information Regarding Referred Transactions
If a HAH Auto Company refers you to an independent business (e.g. a car dealer, lender or credit card company) for a proposed transaction (e.g. a vehicle purchase, loan or credit card), then the HAH Auto Company may collect from that independent business information regarding the transaction to update your confidential profile for use by HAH Auto Group as set out in this Privacy Policy.

4. How HAH Auto Group Uses Personal Information

(a) General
Each HAH Auto Company uses your personal information collected by the HAH Auto Company for purposes relating to or arising from your relationship and transactions with the HAH Auto Company and as otherwise set out in this Privacy Policy or permitted by applicable law, including:

• to administer your relationship with HAH Auto Group, including to create and manage your account or membership with HAH Auto Group and to contact and correspond with you regarding those matters;
• to facilitate your interactions and transactions with HAH Auto 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 HAH Auto 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 HAH Auto Group;
• to maintain, protect and improve HAH Auto Group’s products and services and to develop new products and services;
• to protect and enforce HAH Auto Group’s legal rights, interests and remedies and to protect the business, operations and customers of HAH Auto Group or other persons; and
• to assist other HAH Auto Companies to collect, use, disclose and retain your personal information in accordance with this Privacy Policy.

(b) HAH Auto Group
A HAH Auto Company may share your personal information with the entire HAH Auto Group, and the HAH Auto Group may develop, maintain and share a confidential profile for you for use by each HAH Auto Company to provide information, products and services to you, to facilitate your dealings with each HAH Auto Company and as otherwise set out in this Privacy Policy.

(c) Interest-Based Advertising
The HAH Auto 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 HAH Auto 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 HAH Auto Group websites – to display ads based on the computer’s past access to HAH Auto 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.

5. How HAH Auto Group Discloses Personal Information

(a) General
Each HAH Auto Company discloses your personal information for purposes relating to or arising from your relationship and transactions with the HAH Auto Company and as otherwise set out in this Privacy Policy or permitted by applicable law.

(b) Specific Consents
A HAH Auto Company may disclose your personal information in accordance with express or implied consents that you give during your interactions and transactions with the HAH Auto Company.

(c) Referred Transactions
If a HAH Auto Company refers you to an independent business (e.g. a car dealer, lender or credit card company) for a proposed transaction (e.g. a vehicle purchase, loan or credit card application), then the HAH Auto Company may disclose your personal information (including your credit score that you provided to a HAH Auto Company, bank account information, and related information) to the independent business to facilitate the proposed transaction. HAH Auto 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 HAH Auto Company may disclose your personal information to its suppliers and service providers (including fraud prevention services and payment processors) to assist the HAH Auto Company in the provision of information, products and services to you, to provide services to the HAH Auto Company, to assist the HAH Auto 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 HAH Auto 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 HAH Auto Company may disclose your personal information to law enforcement agencies or other independent organizations if the HAH Auto 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 HAH Auto Company reasonably believes the disclosure is necessary or appropriate to protect and enforce the HAH Auto Company’s legal rights, interests and remedies or to protect the rights, interests, business, operations or customers of the HAH Auto 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 HAH Auto Company’s products or services). A HAH Auto 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 HAH Auto 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 HAH Auto Company may disclose your personal information in connection with a proposed or actual business transaction in which the HAH Auto Company is involved (such as a corporate amalgamation, reorganization, merger or acquisition, or the sale or transfer of some or all of the HAH Auto Company’s business or assets), but the HAH Auto 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.

6. Location of Personal Information

HAH Auto 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 HAH Auto 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.

7. Retention of Personal Information

HAH Auto 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 HAH Auto Group’s legal obligations or enforce or protect HAH Auto Group’s legal rights, or a longer period required or permitted by applicable law. HAH Auto Group will delete or dispose of your personal information when HAH Auto Group is no longer reasonably required to retain the information for the purposes set out or referenced in this Privacy Policy.

8. Protection of Personal Information

HAH Auto Group uses reasonable safeguards – including administrative, physical and technical security and safeguarding measures – appropriate to the sensitivity of the personal information in HAH Auto Group’s possession or under HAH Auto 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 HAH Auto Group cannot guarantee that your personal information will not be used, disclosed or deleted in ways not otherwise described in this Privacy Policy.

9. Accuracy and Access to Personal Information

HAH Auto Group will rely on you to ensure that your personal information that you provide to HAH Auto Group is as accurate, complete and up to date as necessary for the purposes for which HAH Auto Group uses the personal information. You will promptly notify HAH Auto Group of any changes to your personal information using the procedures made available for that purpose by HAH Auto Group or by contacting HAH Auto Group’s customer service.

You may reasonably request access to your personal information collected by HAH Auto Group and information about HAH Auto Group’s use, disclosure and retention of that personal information by submitting a written request to HAH Auto 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. HAH Auto 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.

9. Non-Personal Information

HAH Auto 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. HAH Auto 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 HAH Auto 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.

11. Other Websites and Businesses

HAH Auto Group’s websites and correspondence (including emails and messages) may include advertisements for products and services (e.g. vehicle sales, personal loans and credit cards) offered by independent businesses (that may have a financial relationship with a HAH Auto Company) or links to websites operated by independent businesses (e.g. car dealers, lenders and credit card providers). HAH Auto 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.

12. Other Matters

(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 HAH Auto Group’s products or services contain important provisions, including provisions disclaiming, limiting or excluding the liability of HAH Auto 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 HAH Auto 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 HAH Auto Company may change this Privacy Policy from time to time by posting a new version of this Privacy Policy on the HAH Auto Company’s website. A HAH Auto 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 HAH Auto 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 HAH Auto 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 HAH Auto Group’s Chief Privacy Officer:
If you have any comments or questions about this Privacy Policy or how HAH Auto Group deals with your personal information, please contact HAH Auto Group’s Chief Privacy Officer by mail or email at: HAH Auto Group – Chief Privacy Officer, Suite 600, Two Bentall Centre, 555 Burrard Street, Vancouver, British Columbia, Canada, V7X 1M8; email: privacy@canadadrives.ca