Client Personal Information

At Class “A” Automotive, we have a firm commitment to protecting your privacy and security as our client. Information that can identify you (called “personal information” in this policy) is sometimes required for a business transaction. We do not consider public information found in directories and listings, or business names, addresses and/or contact numbers to be personal information.

This document summarizes what personal information we may collect, how we might use this information and the steps we take to ensure your personal information is handled appropriately. It also describes other important topics relating to your privacy.

Our policies and practices are designed to comply with the Personal Information Protection and Electronic Documents Act (PIPEDA) and corresponding provincial privacy acts. We have adopted, as company policy, the ten personal information privacy principles stated in the Canadian Standards Association (CSA) Model Code for the protection of personal information.

Accountability
Class “A” Automotive is responsible for all personal information under its control, including any personal information that is transferred to third parties for processing, storage or other purposes.

We have employees who are specifically responsible for our compliance with the principles of the CSA Code. Their responsibilities include making sure third parties processing personal information on our behalf provide a comparable level of protection.

Identifying Purposes
Class “A” Automotive will identify and document the purpose(s) for which your personal information is collected, used, or disclosed at or before the time of collection.

The purpose(s) will be limited to those that are related to our business and that a reasonable person would consider to be appropriate under the circumstances. Class “A” Automotive will only collect personal information (such as, but not limited to, name, address, telephone number) that is required for the proper functioning of our business.

Class “A” Automotive will use the information you provide to:

• Fulfill your service needs
• Efficiently process and document your business transactions
• Respond to your inquiries with information about Class “A” Automotive and our services
• Develop, implement, market, and manage services and contests for clients. We may merge personal information with data obtained from third parties for the same purpose.
• Assist in law enforcement purposes, to collect unpaid debts and to protect the business interests of Class “A” Automotive and its clients
• Manage and promote the business activities of Class “A” Automotive
• Meet requirements imposed by law.

Web Site – What Information We Collect and How It is Used
Personal Information – We do not automatically gather any personal information from you, such as your name, address, phone number, or e-mail address. This information is only obtained if you provide it voluntarily, usually through contacting us via e-mail.

If you decide not to provide us with personal information, no material consequences will result, although you may be unable to participate in certain promotions, receive product information, or use portions of our Web site that require personalized information or applications.

Non-Personal Information – We use software that receives and records the Internet Protocol (IP) address of the computer that has contacted our Web site. We make no attempt to link these addresses with the identity of individuals visiting our site.

Cookies – A cookie is a small data file that certain Web sites write to your hard drive when you visit them. A cookie file may contain information such as user ID that the site uses to track the pages you have visited, but the only personal information a cookie can contain is information you provide. A cookie cannot read data from your hard drive or read cookie files created by other sites. Some parts of “classaautomotive.ca” may use cookies to track user traffic patterns. Class “A” Automotive does not correlate this information with data about individual users, nor does it share this information or sell it to any third party.

We may use data collected from our Web site to tailor the visitor’s experience at our site, showing them content that we think they might be interested in, and displaying the content according to their preferences.

Information and cookies may be used to measure a number of visits, average time spent on the site, pages viewed, and other relevant statistics. We may collect this information to measure the use of our site and to improve the content.

As part of our commitment to enhancing client service, Class “A” Automotive may identify other uses for your personal information. In that event, your consent will be required prior to using your information for any new purpose.

Consent
Personal information will only be collected, used, or disclosed with the knowledge and consent of the individual when appropriate.

The way we seek consent, including whether it is express or implied, may vary depending upon the sensitivity of the information and the reasonable expectations of the individual. An individual can withdraw consent at any time, notwithstanding legal or contractual restrictions and reasonable notice. Individuals will be informed of any implications of withdrawing consent.

We endeavour to seek consent for the use or disclosure of information at the time of collection. In certain circumstances (for example, when we want to use personal information for a purpose not previously identified) consent may be sought after the information has been collected but before use.

In general, the purchase of Class “A” Automotive products and services constitutes implied consent for Class “A” Automotive to collect, use, disclose, and retain information for the purposes identified in this policy.

As permitted or required by law we may collect, use or disclose personal information without the knowledge or consent of the individual in certain circumstances.

These circumstances include:

• Personal information subject to solicitor-client privilege or publicly available as defined by regulation
• Collection or use of personal information is clearly in the interests of the individual and consent cannot be obtained in a timely manner
• Investigations relating to an actual or perceived breach of an agreement, contract, or a contravention of a law
• Acting in respect to an emergency that threatens the life, health and/or security of an individual or other individuals
• Debt collection
• Complying with a subpoena, warrant or court order.

Web Site
If you prefer not to receive cookies from “classaautomotive.ca”, you can set your computer’s Web browser to warn you before accepting cookies and refuse the cookie when your browser alerts you to its presence. You can also refuse all cookies by turning them off in your browser. This could affect the areas of the Web site that are accessible to you.

Marketing
Class “A” Automotive may release certain client information (specified below) to outside firms for the purpose of distributing promotional marketing materials or client follow-up initiatives. The information released will only include personal information necessary to complete the appropriate task and limited to only the information specified below:

• Name
• Mailing Address
• Phone number
• Email address

Class “A” Automotive will only enter into an agreement of this type with outside firms that have policies in place to protect our client’s personal information and adhere to the stipulations within the Class “A” Automotive privacy policy.

Limiting Collection
We will limit the amount and type of personal information collected to what is necessary for our identified purposes. We will only collect personal information by fair and lawful means.

Limiting Use, Disclosure, and Retention
Personal information will not be used or disclosed for purposes other than those for which it was collected, except, as previously stated, with the consent of the individual or as required by law. Personal information will be retained only as long as necessary to fulfill the identified purposes.

Personal information that has been used to make a decision about an individual will be retained long enough to allow the individual access to the information after the decision has been made and, in the event of an access request or a challenge, long enough to exhaust any recourse an individual may have under the law.

If required by law or an investigative body, Class “A” Automotive may also be required to release your personal information. Class “A” Automotive will have no legal liability for such disclosures.

If personal information is no longer required to fulfill the identified purposes, it will be destroyed, erased, or made anonymous.

Accuracy
We will be prudent in our efforts to ensure personal information is as accurate, complete, and up-to-date as necessary for the purpose(s) for which it is to be used.

Safeguards
We will protect personal information with safeguards appropriate to the sensitivity of the information. Regardless of the format in which it is held, the safeguards we will take include:

• Physical security measures such as restricted access facilities and locked filing cabinets
• Electronic security measures for computerized personal information such as password protection and encryption
• Organizational processes such as security clearances and limiting access on a “need-to-know” basis
• Contractual obligations with third parties who need access to your personal information requiring them to protect and secure your personal information.

Web Site
Class “A” Automotive and its Internet Service Provider use precautions to keep the personal information disclosed to us secure. We are not, however, responsible for any breach of security. Class “A” Automotive also links to sites of other reputable companies. We are not responsible for their privacy policies or how they treat information about their users.

Openness
We are committed to providing you with understandable and easily available information about our policy and practices related to management of your personal information. This policy and any related information is available at all times on our Web site, under Privacy Policy, or upon request.

Individual Access
Upon written request, we will inform an individual of the existence, use, and disclosure of his or her personal information and we will give the individual access to that personal information in an appropriate format. An individual can challenge the accuracy and completeness of his or her personal information and have it amended as appropriate.

We will respond to the written request of an individual within a reasonable time, usually within 30 days. We may require the individual to provide sufficient information to permit us to provide an account of the existence, use, and disclosure of personal information. Requested information will be provided or made available in a form that is generally understandable.

If an individual successfully demonstrates the inaccuracy or incompleteness of personal information, we will amend the information as required. If a challenge is not resolved to the satisfaction of the individual, we will record the substance of the unresolved challenge.

In certain situations, we may refuse a request or not be able to provide access to all the personal information we hold about an individual. Exceptions to the access requirement will be limited and specific, as permitted or required by law. Where permitted, the reasons for denying access will be provided to the individual upon request. Exceptions may include:

• Information that contains references to other individuals or contains confidential information, where such information cannot be severed from the record
• Information collected in the course of investigating a breach of an agreement, contract, or during the course of a formal dispute resolution process
• Information that is subject to solicitor-client privilege.

We will take every precaution to ensure the individual requesting the information is indeed the individual who is entitled to the information.

Challenging Compliance
Our Privacy Policy is regularly reviewed to ensure we continue to serve the privacy interests of our clients. We reserve the right to change and update the Privacy Policy and these changes will be posted in a timely manner.

If you have questions regarding our Privacy Policy, the security of your personal information or our compliance with the Personal Information Protection and Electronic Documents Act (PIPEDA) or similar provincial legislation, contact us.

We will investigate all written complaints. If we find a complaint to be justified, we will take all appropriate measures, including, if necessary, amending our policies and practices.