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, Milltown Motors Limited 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.]
Milltown Motors Limited 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 Milltown Motors Limited 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 Milltown Motors Limited];
- to manage its General Motors Milltown Motors Limited business and ensure the efficiency, reliability and security of its systems and networks;
- to meet legal and regulatory requirements and allow Milltown Motors Limited to meet contractual requirements relating to the products and services provided to customers;
- to ensure its records are accurate and to protect customers and Milltown Motors Limited 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 Milltown Motors Limited, 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 Milltown Motors Limited as well as other career development resources.
Milltown Motors Limited 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 Milltown Motors Limited 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, Milltown Motors Limited 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 Milltown Motors Limited 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 Milltown Motors Limited 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 Milltown Motors Limited 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 Milltown Motors Limited 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, Milltown Motors Limited 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.
[Milltown Motors Limited TO DETERMINE WHAT APPLIES TO Milltown Motors Limited SHIP ONLINE ACTIVITY]
Milltown Motors Limited 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:
Requests for Product and/or Service.
- 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:
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.
We use Google AdWords Remarketing to advertise Milltown Motors Limited 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 Milltown Motors Limited 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].
Milltown Motors Limited 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).]
Your Choice with Cookies.
Privacy Policies of Third Parties.
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. Milltown Motors Limited 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 Milltown Motors Limited itself.
Security of Personal Information
We will use reasonable security measures to protect your personal information against unauthorized access. Milltown Motors Limited 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. Milltown Motors Limited has developed and implemented retention procedures, and will ensure destruction of personal information in a method that prevents improper access.
Access and Correction
Milltown Motors Limited 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
Protecting the privacy and confidentiality of personal information is an important aspect of the way Milltown Motors Ltd. conducts its business. Collecting, using, and disclosing personal information in an appropriate, responsible, and ethical manner is fundamental to Milltown Motors Ltd.’s daily operations.
Milltown Motors Ltd. strives to protect and respect personal information of its customers, employees, business partners, and so on in accordance with all applicable regional and federal laws. Each staff member of Milltown Motors Ltd. must abide by this organization’s procedures and practices when handling personal information.
Personal information is defined as any identifying information about an individual or group of individuals, including name, date of birth, address, phone number, e-mail address, social insurance/security number, nationality, gender, health history, financial data, credit card numbers, bank account numbers, assets, debts, liabilities, payment records, credit records, loan records, opinions, and personal views. Business information is defined as Milltown Motors Ltd., business address, business telephone number, name(s) of owner(s), executive officer(s), and director(s), job titles, business registration numbers, and financial status. Business information is treated and handled with the same level of confidentiality, privacy, and respect as personal information.
Consent occurs and is obtained when an individual signs an application or other form containing personal information, thereby authorizing Milltown Motors Ltd. to collect, use, and disclose the individual’s personal information for the purposes stated on the form or in the Appropriate Use section of this policy.
• Implied consent is granted by the individual when he/she signs the application or form. This allows Milltown Motors Ltd. to obtain or verify information from third parties (such as banks, credit bureaus, lenders, or insurance companies) in the process of assessing the eligibility of an individual, customer, client, job applicant, or business partner.
Milltown Motors Ltd. collects and uses personal information solely for the purpose of conducting business and developing an understanding of its customers. Milltown Motors Ltd. hereby asserts that personal information will only be used for the following purposes:
- Obtaining Credit score and or credit approval
- Consent for repairs and or sales of product
- Building our database to allow use to interact with you our customer
- Info needed to share with our franchise holder General Motors and Third party suppliers that require the information in order for use to provide sales, service or parts to you during the course of our business relationship.
• Milltown Motors Ltd. assumes full accountability for the personal information within its possession and control. This organization has appointed Don Lees Jr., Heidi Lees and or Frank Graham as custodians of all privacy matters and legal compliance with privacy laws.
• Milltown Motors Ltd. obtains personal information directly from the individual to which the information belongs. Individuals are entitled to know how Milltown Motors Ltd. uses personal information and this organization will limit the use of any personal information collected only to what is needed for those stated purposes. Milltown Motors Ltd. will obtain individual consent if personal information is to be used for any other purpose. Milltown Motors Ltd. will not use that information without the consent of the individual.
• Under no circumstances will Milltown Motors Ltd. sell, distribute, or otherwise disclose personal information or contact lists to third parties. However, limited disclosure may be required as part of Milltown Motors Ltd. fulfilling its stated business duties and day-to-day operations. We may share some or all of your personal information with General Motors of Canada Company (“GM”) and its affiliates and/or the providers of products or services relating to your vehicle such as: credit reporting agencies, financial institutions or financing companies, your insurance agent or company and companies which provide or insure warranties relating to your vehicle. This information will be collected, used and disclosed by us and by General Motors in accordance with their respective privacy policies, copies of which can be found for Milltown Motors Limited on https://www.milltownmotorsltd.com/ and for GM, at gm.ca http://www.gm.ca/gm/english/corporate/about/privacy/overview , including information about your options for how they collect, use and disclose your personal information.
• Milltown Motors Ltd. will retain personal information only for the duration it is needed for conducting business. Once personal information is no longer required, it will be destroyed in a safe and secure manner. However, certain laws may require that certain personal information be kept for a specified amount of time. Where this is the case, the law will supersede this policy.
• Milltown Motors Ltd. vows to protect personal information with the appropriate security measures, physical safeguards, and electronic precautions. Milltown Motors Ltd. maintains personal information through a combination of paper and electronic files. Where required by law or disaster recovery/business continuity policies, older records may be stored in a secure, offsite location.
o Access to personal information will be authorized only for the employees and other agents of Milltown Motors Ltd. who require the information to perform their job duties, and to those otherwise authorized by law.
o Milltown Motors Ltd.’s computer and network systems are secured by complex passwords. Only authorized individuals may access secure systems and databases.
o Active files are kept in locked filing cabinets.
o Routers and servers connected to the Internet are protected by a firewall, and are further protected by virus attacks or “snooping” by sufficient software solutions.
o Personal information is not transferred to volunteers, summer students, interns, or other non-paid staff by e-mail or any other electronic format.
o Personally identifiable information about the individual that is collected from the Web site or through affiliate sites.
o Information about the organization collecting the data.
o How the data will be used.
o With whom the data may or may not be disclosed.
o What options are available to the individual regarding the collection, use, and disclosure of personal information?
o The information technology security procedures in place that protect against the destruction, loss, theft, alteration, or misuse of personal information under Milltown Motors Ltd. possession and control.
o How the individual may access and correct any inaccuracies in their personal information.
o Milltown Motors Ltd. may share compiled demographic information with its business partners and/or advertisers, but no personal information that can identify any individual person shall be disclosed.
o This Web site may contain links to other sites, but Milltown Motors Ltd. is not responsible for the privacy practices of other organizations’ sites.
o While IP addresses will be logged in order to administer the site, track visitor movement, and gather demographic information, these IP addresses will not be linked to any personally identifiable information.
o Any registration or order form asking site visitors to enter personal or financial information will be protected by SSL encryption.
o Site visitors are given the choice to opt out of having their personal information used at the point where the information is gathered.
• In most instances, Milltown Motors Ltd. will grant individuals access to their personal information upon presentation of a written request and satisfactory identification. If an individual finds errors of fact with his/her personal information, please notify Milltown Motors Ltd. as soon as possible to make the appropriate corrections. Should Milltown Motors Ltd. deny an individual’s request for access to his/her personal information, Milltown Motors Ltd. will advise in writing of the reason for such a refusal. The individual may then challenge the decision.
• Milltown Motors Ltd. may use personal information without the individual’s consent under particular circumstances. These situations include, but are not limited to:
o Milltown Motors Ltd. is under obligation by law to disclose personal information in order to adhere to the requirements of an investigation of the contravention of a regional or federal, under the purview of the appropriate authorities.
o An emergency exists that threatens an individual’s life, health, or personal security.
o The personal information is for in-house statistical study or research.
o The personal information is already publicly available.
• Disclosure is required to investigate a breach of contract.