iCarBuyer

1. What Personal Information Does iCarBuyer Collect?

Personal information is information about an identifiable individual. Personal information collected by iCarBuyer may include information such as your first and last name, home or other physical address, email address, zip code, telephone number, social security number, date of birth, information relevant to accessing your creditworthiness, your automobile’s make, model, trim, model year, mileage, color, options, vehicle identification number (“VIN”), license plate number, or information about your interactions with us or others, and other information. We may also collect demographic information such as a customer’s gender; age and occupation, to better understand our customers and service their needs and for marketing purposes.

Visitors to iCarBuyer’s Site are not required to register or provide personal information to gain access. However, to utilize certain features of the Site iCarBuyer requires visitors to register with the Site and provide certain personal information, such as their name, postal code, and email address or authentication information. Additionally, as iCarBuyer’s Site evolves and becomes more interactive, and as the Site becomes a repository for increasingly personalized customer information, iCarBuyer may require visitors to register and provide user identification or authentication information to access certain other portions of the Site.

Sensitive personal information can include a number of types of information relating to an individual’s race or ethnic origin; political opinions; religious or other similar beliefs; trade union membership; physical or mental health; sexual orientation or criminal record. We do not require individuals to provide, such sensitive personal information. We do not solicit sensitive personal information and recommend that you do not provide such sensitive information. If you voluntarily provide sensitive personal information for any reason, you understand and agree that by doing so you have provided your express consent to iCarBuyer to use that information in the manner described in this Privacy Policy, or for the purpose(s) described to the individual at the time the information was provided.

iCarBuyer may collect personal information in one, or more, of the following circumstances:

Information You Provide.

We may collect and retain any information from you or your devices provided to us when you visit the Site, including when you:

Use our Service or mobile application(s)
Register for an account
Apply for financing
Communicate with us
Such as to provide feedback
Request support
Or ask for additional information

If you register for an iCarBuyer account directly through the Service, you will be required to provide your first name, last name, postal code, email address and create a password. You may also choose to provide a profile picture in connection with your iCarBuyer account. If you enter a drawing or giveaway offered through the Service you will be required to provide your postal address, including the street address, city, state and zip code. You may also choose to provide additional information that can be used to pre-approval data for banks and lenders to review. Information such as your planned date of purchase, postal address, date of birth, home ownership status, and employment information may also be required, provided, and collected. Providing this additional information is optional and you are not required to provide this information in order to use the Service.

Social Media.

you may use social networks or other online services to access our Sites. When you do so, information from those services may be made available to us. By connceting a social media account with or to our Sites, you agree that we may access and retain that information in accordance with the policies of the social media platform or other online service and this Privacy Policy. For clarity, that may include your account or profile information that you have provided to the social network or information about your interactions with the social media platform to make information available to us. You may generally control those choices through the setting selected on your social media account.

Automatically Collected.

When you visit the Site, we may collect information that is automatically sent to us by your web browser or your internet service provider. This information may include your domain name, and your numerical IP address, the pages you visit, vehicles you view or configure, and the features you use, including dates and times. We may also collect other general information (such as the type of browser you use, which pages on our Site you view, and the files you request).

Cookies and Other Technologies.

When you visit websites on the Internet, your browser may automatically transmit information to the websites you visit throughout every visit, including ours. Like many websites, we use “cookies”. A cookie is a small data file that we transfer to your computer’s hard disk.

We utilize persistent cookies that only iCarBuyer can read and use, and access mobile device IDs:

To save your login information for future logins to the Site
To hold session information
And to track user preferences

We utilize session ID cookies and similar technologies:

To enable certain features of the Site
To better understand how you interact with the Site
To monitor usage by our visitors and web traffic routing on the Site
And to identify visited areas of the Site

Unlike persistent cookies, session cookies are deleted from your computer when you log off from the Site and then close your browser.

You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you will not be able to use all portions or all functionalities of the Site.

We and our service providers may also use “pixel tags”, “web beacons”, “clear GIFs”, or similar means in connection with the Site and HTML-formatted email messages to, among other things, track the actions of visitors and email recipients, to determine the success of marketing campaigns, and to compile statistics about Site usage and response rates. We may also engage one or more third party service providers to serve online advertisements on our behalf. They may use a “pixel tag” which triggers a cookie to collect information about your visits to the Site and to other websites, and they may use that information and share and combine it with other information with their partners to show you advertisements for goods and services you might be interested in on the Site and on other websites and apps, including by observing the kinds of products and subject-matter you are interested in and certain demographic information about you.

The following table sets out the different categories of cookies that the Site may use and why we would use them. The lists of third party cookie providers are intended merely as illustrative not comprehensive:

Type of Cookie	Purpose	Who Serves (for example)
Authentication Cookies	These cookies (including local storage and similar technologies) tell us when visitors are logged in so we can customize their experience and connect their account information and settings.	iCarBuyer
Localization	These cookies help provide a localized experience by showing you your local area, for example, dealerships.	iCarBuyer
Site features and Services	These provide functionality that help us deliver products and the Site. For example, cookies help you log in by pre-filling fields. We may also use cookies and similar technologies to help us provide you and others with social plugins and other customized content and experiences, such as making suggestions to you and others.	iCarBuyer
Analytics and research	These are used to understand, improve, and research products and services, including when you access the Site and related websites and apps from a computer or mobile device. For example, we may use cookies to understand how you are using site features, and segmenting audiences for feature testing. We and our partners may use these technologies and the information we receive to improve and understand how you use the Site.	iCarBuyer

Third Parties.

If you visit the Site from a third-party website the third-party website may give you a unique code, cookie or graphic which will uniquely identify you. This will only happen if you link directly from a third-party website to the Site. Your activities on the Site while this type of code is active may be reported back to the third-party website. The presence of a third-party navigation bar at the top of a webpage is an indication that the third-party website may be able to see your activity on the Service.

In addition, if you access the Site through the Internet, your browser may allow you to adjust your browser settings so that “Do Not Track” requests are sent to the websites that you visit. However, iCarBuyer will not disable tracking technology that may be active on the Site in response to any “do not track” requests that we receive from your browser.

Mobile.

We may collect session and geolocation information from your mobile device. Geolocation information includes data such as your device’s physical location and may include GPS-based, WiFi-based or cell-based location information.

Information from Other Sources.

We may obtain information about you from affiliates, partners, vehicle dealers and other third parties. This information may include information about your use of this Site or our services, your use of other websites, your interactions with or purchases from automotive dealers, your interests and preferences and other information about you or your household. We may combine the information we obtain from third parties with information that we or our affiliates have collected about you

2. How Is Your Personal Information Used?

We and others acting on our behalf may use the information that we collect or receive to operate our business, including our Sites, as described below:

Operate and Support our Sites and Services.

We use the information that we collect and receive in order to operate our Sites and our Services. For example, we may use the information that we collect or receive to provide support and assistance to you and other visitors or to address technical problems in the operation of our Sites or any of our Services. If you create an account with us, we may use information about you to manage or support your account. We may identify your use of our Sites across devices, and we may use information we collect from you and receive from others to optimize your use of the Sites and our Services as you use different devices.

To Allow You to Connect with Dealers.

When you use our Service, and after you provide your contact information in order to request offers or information, we may use the information you provide us to allow you to connect with automobile dealers. The dealers we communicate with may provide you a savings certificate and/or with an offer(s) for new or used vehicles or other products or services, depending on the information submitted. We may also notify a dealer when you are at the dealer’s location via geolocation information that we collect. When you choose to share your contact information with dealers, your direct interactions with those dealers will not be controlled by this Privacy Policy. You should review the applicable privacy policies of those dealers to understand how they may use your information.

To Allow You to Connect with Lending Institutions.

Our Sites and Services may permit you to provide information relevant to your creditworthiness or financial status, potential financing, and creditworthiness. Your direct interactions with lending institutions will not be controlled by this Privacy Policy. You should review the applicable policies of those lending institutions to understand how they may use your information. You may limit our sharing of certain information provided to us in connection with the potential financing of a vehicle. If you limit this sharing, you may be limited in receiving financing offers from certain dealers and/or lending institutions.

Automobile Dealers, Manufacturers, Lending Institutions.

We may share information with automotive dealers, manufacturers and other providers of automotive related products and services. For example, we may share information with our participating dealers to allow you to communicate with them, and them to communicate with you. The information we share may include information regarding your creditworthiness or your interest in particular vehicles. Such information may be shared with third parties who support our Site, credit reporting agencies, dealers, lending institutions, and others. These parties may provide you with offers for loans or other products or services.

Advertising and Promotions.

We may use the information we collect to offer, provide, or personalize products and services from us and third parties. For example, we may customize content, advertising, promotions and incentives to reflect your preferences, interests, or prior interactions with us and others.

Other Contacts.

We may contact you through telephone, text, email, or chat for other purposes, as permitted by law.

This Privacy Policy only addresses our own information practices. This Privacy Policy does not apply to information you share with third parties, including but not limited to dealers and lending institutions, even if we link to those third parties from the Site. These third parties may have their own privacy policies governing their use of information that you can access from their websites.

3. When Does iCarBuyer Share Your Information?

We only share information about you as described or permitted by this Notice, unless you consent to other sharing. We may share information about you in the following ways and for the following purposes:

to provide access to the Service and to provide you with requested services and customer support and to process and respond to your inquiries
personalize, customize, measure, and improve our Services, content, and advertising and otherwise to enhance your experience of the Service
prevent, detect, and investigate potentially prohibited or illegal activities, and enforce the iCarBuyer terms and conditions use
analyze the accuracy, effectiveness, usability, or popularity of the Service
generate and review reports and data about our user base and service usage patterns
compile aggregate data for internal and external business purposes
resolve disputes and troubleshoot problems
contact you with information, including promotional, marketing and advertising information and recommendations that we believe may be of interest to you
provide you with other services requested by you as described when we collect the information
provide you with information we deem relevant when you visit third party merchant locations
if you use the Service on a mobile device, with your consent, we may send push notifications to your mobile device to provide updates about the Service and other relevant messages. You can manage push notifications from the “Settings” page within your account. You may also be able to manage them from your mobile device’s settings page

Corporate Affiliates.

We may share information with our corporate affiliates for their everyday business purposes, to provide services or to perform marketing. We may also participate in joint ventures with others and we may share information as part of that joint venture.

Partner Sites.

We may share the information we gather with partner sites (and the owners of those sites). For example, we may share information for the purpose of determining or verifying our economic rights and obligations.

Service Providers.

We may share information with third party service providers who help us operate our business or provide services on our behalf, including third parties who help us operate our Sites. These service providers include analytics companies and advertising networks that provide Metrics Tools on our Sites.

Automobile Dealers, Manufacturers, Lending Institutions.

We may share information with automobile dealers, lenders, manufacturers and other providers of automobile related products and services. For example, we may share information with certain automobile dealers to allow you to communicate with them, and them to communicate with you. The information we share may include information regarding your creditworthiness or your interest in particular vehicles. Such information may be shared with third parties who support our website, credit reporting agencies, dealers, lending institutions, and others. These parties may provide you with offers for loans or other products or services.

Business Transfer.

We may share information we have collected from you in connection with the sale or merger of our business or the transfer of assets.

Aggregate Information.

iCarBuyer may share information relating to visitors and users of the Site with affiliated or unaffiliated third parties on an aggregate basis. We note that, while this information will not identify you personally, in some instances these third parties may be able to combine this information with other data they have about you, or that they receive from third parties, in a manner that allows them to identify you personally.

Legal Basis for Processing Your Information.

iCarBuyer may collect, store, and/or process your personal information because:

We have a legally binding contract with you
You have given consent to do so
We are providing services to you through the Site
And/Or To comply with applicable law.

For of these reasons, iCarBuyer may legally collect, store, and/or process the personal information we have about you.

4. How Long Does iCarBuyer Retain Your Personal Information?

Consistent with Canadian privacy law, iCarBuyer retains your personal information only as long as necessary to fulfill the stated purpose(s) for its collection and use. iCarBuyer reserves the rights to otherwise retain your personal information as may be required or permitted by law.

5. What Right Do You Have to Access and Update Your Information?

You have the right to access, verify and correct your personal information collected by iCarBuyer. To help us keep your personal information current, you may contact iCarBuyer at info@icarbuyer.com.

When you ask to access your personal information, iCarBuyer will use reasonable efforts to comply with your request; however, in some cases we may not be able to allow you to access certain personal information in certain circumstances, for example if it contains personal information of other persons, or for legal reasons. In such cases, we will provide you with a reasonable explanation of why it is not possible to grant access to your personal information.

To the extent permitted by law, iCarBuyer assumes no responsibility for verifying the ongoing accuracy of personal information. Once advised that personal information is inaccurate, iCarBuyer will seek to amend the information and correct it with information provided by the customer.

6. Residents of the EEA.

If you are currently a resident of the European Economic Area (“EEA”) you have certain rights related to your personal information. Below are the rights that you have under applicable law, and what iCarBuyer does to protect and preserve those rights. If you have a question about any of the rights below, or would like to exercise any of these rights, please contact iCarBuyer at info@icarbuyer.com.

Legal right	What iCarBuyer Does
The right to be informed	iCarBuyer has created and published this Privacy Policy to keep you and other users informed as to what iCarBuyer does with your information. We strive to be transparent about how we use your personal information.
The right to access	You have the right to access your information and personal information. Please contact iCarBuyer if you have any questions about our practices or wish to access the personal information we have about you.
The right to rectification	If any of the information or personal information iCarBuyer has about you is inaccurate or not complete, you have the right to ask iCarBuyer to correct it. iCarBuyer must also ask any third parties to correct any such data in their possession if it has passed onto them in accordance with this Privacy Policy.
The right to erasure	If you would like iCarBuyer to erase all of your personal information in its possession and iCarBuyer does not have a legal reason to continue to process and store it, we will erase your personal information in accordance with your request and this Privacy Policy.
The right to restrict processing	You have the right to ask iCarBuyer to restrict how your personal information is processed. In that case, iCarBuyer will keep just enough data to make sure we respect your request in the future.
The right to object	You may, at any time, object to how iCarBuyer is processing your personal information, even if it is being done so in accordance with this Privacy Policy.
The right to withdraw consent	If you have previously given iCarBuyer your consent to process your personal information, but later change your mind, then you have the right to withdraw your consent, at any time, and iCarBuyer will stop processing your personal information.
The right to complain to a Supervisory Authority	You have the right to complain to a supervisory authority if you feel that iCarBuyer has not responded to your requests or complaints. You may find your supervisory authority here: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm

In addition to the rights available to EEA residents above, anyone utilizing our Services may have options available under applicable law. If you would like to request to review, correct, or delete personal information that you have previously provided to iCarBuyer, or if you would like to request to receive an electronic copy of your personal information in order to transmit the personal information to another company (to the extent the right to data portability is provided to you by applicable law), you may contact us at info@icarbuyer.com. In your request, please specifically state what personal information you would like to access. We may require that you verify your identity, in accordance with applicable law, before responding to any such requests. We will respond to and process all requests consistent with applicable law.

If you are a resident of California, under 18 years of age, and are a user of the Site, you may ask us to remove content, information, and/or personal information that you have provided to iCarBuyer by writing to info@icarbuyer.com.

Please note that your request will not ensure complete or comprehensive removal of the information or personal information.

7. How is Your Information Secured?

iCarBuyer treats your information as private, confidential information and we strive to protect that information, both on-line and off-line, at all times. iCarBuyer has implemented generally accepted physical, technological and operational security systems to help protect personally identifiable information from loss, theft, misuse, alteration or destruction. All iCarBuyer employees, agents and selected dealers are instructed about this Privacy Policy and are required to adhere to our security policy. Only personnel authorized by iCarBuyer have access to personal information and these individuals are contractually required to preserve the confidentiality of this information. Personal information we collect is maintained in Ottawa, Ontario.

Although we have taken reasonable and prudent measures to protect our Site, computer systems and any personal information that it has collected from unauthorized use, access, disclosure, misuse, alteration or destruction, no security measures can provide absolute protection. As a result, while we are committed to protecting your personal information, we cannot ensure or warrant the security of any information you provide to us.

Some or all of the personal information we collect may be stored or processed on servers located outside your jurisdiction of residence, including outside of the United States, whose data protection laws may differ from the jurisdiction in which you live. As a result, this information may be subject to access requests from governments, courts, or law enforcement in those jurisdictions according to laws in those jurisdictions. Subject to applicable laws in such other jurisdictions, we will use reasonable efforts to ensure that appropriate protections are in place to require the data processor in that country to maintain protections on the personal information that are equivalent to those that apply in Canada.

8. California Privacy Rights.

Pursuant to California Civil Code Section 1798.83, California residents who provide us with personal information in obtaining products or services for personal, family, or household use are entitled to request and obtain from us, one time per calendar year, information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If this applies to you, then California law provides that you have the right to submit a request to us at our email address in order to receive information on the categories of customer information that we shared and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year. To obtain this information, please send an email message to info@icarbuyer.com with “Request for California Privacy Information” in the subject line and in the body of your message. We will provide the requested information to you in your email address you provide.

Please be advised that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.

9. No Use by Children.

iCarBuyer is not intended for use by children under the age of thirteen (13). We will never knowingly collect information directly from children under the age of thirteen (13) without verifiable parental consent. If you are under the age of thirteen (13), please do not provide us with information of any kind whatsoever. If you have reason to believe that we may have accidentally received information from a child under the age of thirteen (13), please contact us immediately at info@icarbuyer.com.

10. Changes to the iCarBuyer Privacy Policy

iCarBuyer reserves the right to modify or amend this Privacy Policy at any time and for any reason and as required by law. If iCarBuyer updates this Privacy Policy, the new Privacy Policy will be posted on the Site prior to the changes taking effect. We encourage individuals to check the Site periodically for any updates to this Privacy Policy. Your continued access to and/or use of the Site, continued business with iCarBuyer, or continued submission of personal information to iCarBuyer, after any such changes, constitutes your acceptance of, and agreement to be legally bound by, this Privacy Policy, as revised.

11. Applicable Regulations.

The Controlling the Assault of Non-Solicited Pornography And Marketing (CAN-SPAM) Act of 2003, established the United States’ first national standards for the sending of commercial e-mail and requires the Federal Trade Commission (FTC) to enforce its provisions. iCarBuyer takes steps to ensure iCarBuyer is compliant with CAN-SPAM.

Canada’s Anti-Spam Legislation (CASL) became effective July 1, 2014 and among other things regulates the sending of commercial electronic messages (CEMs) by organizations such as iCarBuyer. iCarBuyer takes steps to ensure iCarBuyer is compliant with CASL.

12. Contact us

If you have any questions regarding this privacy policy, or the collection, use or disclosure of personal information by iCarBuyer, you may contact iCarBuyer at info@icarbuyer.com or by writing us at Paul Kennedy Private Sales, Inc., 7 Rideau Heights Lane Ottawa, Ontario K2E7A7.