Privacy Policy
Your privacy is important and protected by us. ELM Auto Brokers Ltd. (the “Company”) and our affiliates, partners, and nominees (collectively referred to as “we” and “us”) are committed to providing you with excellent service, maintaining a high level of security, and respecting your right to privacy. We are also committed to protecting your rights under the Personal Information Protection Act (within Alberta) and the Personal Information Protection and Electronic Documents Act (elsewhere in Canada).
This privacy statement describes how the Company and our affiliates, partners, and nominees collect, use, disclose, and retain personal and other information from you, and about you, during your visits to our websites, or through social media, mobile phone, and telephone calls, and when we provide you with products and services.
What Is Personal Information?
In this Privacy Statement, “personal information” means information about an identifiable individual, including your name and contact information.
What Does This Privacy Statement Apply To?
This Privacy Statement applies to our collection, use, and disclosure of your personal information except where otherwise permitted by law. For example, many types of personal information that are publicly available (e.g. in a telephone directory) may be collected, used, disclosed, or retained without your consent.
Your Consent
By providing your personal information, you consent to the collection, use, disclosure, and retention of that information by us in accordance with this Privacy Statement and as otherwise permitted by law. You may withdraw this consent at any time, subject to legal and contractual restrictions and on reasonable notice to us. However, you may not then be able to proceed with all intended interactions and transactions or receive the full benefit of our products and services.
When Do We Collect Personal Information?
We collect personal and other information about you when you: request further information or a call back; fill out an application or other form; apply for an account or membership; update your account or membership information; subscribe to a newsletter or information feed; register to receive information; or apply, register for, order, or use a product or service offered by us or to which you are referred by us.
We may collect personal and other information about you from the information you provide to us when you communicate with us by any means, including in person, via telephone, or via electronic services.
We may collect personal and other information about you from credit and consumer reporting agencies, independent businesses, and other persons, including those you have explicitly or implicitly authorized us to contact.
When you apply for, register for, request, order, or use products and services from us, depending on the nature of the product or service, the personal and other information we collect may include: your name, birth date, and address; your Social Insurance Number; telephone numbers; email addresses; social media identity, memberships, webpages, and networks; banking and financial information; credit card numbers; credit histories, reports, and scores; consumer and debt history; and other additional personal and identifying information that we may specifically request from you.
If we refer you to an independent business for a proposed transaction, then we may collect personal and other information from that independent business regarding the transaction to update your profile for use by us in the manner set out in this Privacy Statement.
We may automatically collect information concerning your use of our websites, social media, and other online services, including the dates and times and locations from which you access the services; information about the devices that you use to access the services; and other details of your use of the services. We take steps to ensure that this information is anonymous and does not identify you unless required by law to do otherwise.
Why is Personal Information Collected and Used?
If you fill out an application or another form, we may ask for personal and other information to help us communicate with you; evaluate your eligibility for programs, products, or services; and understand the information, membership, program, or products or services that may be right for you and make offers to you accordingly. We will also obtain other information about you from other sources you authorize us to contact, or from public sources.
Your personal and other information is required to repair or improve your credit, credit score, creditworthiness, and financial status or profile; offer and provide products and services related to credit and financial information; offer and provide debt solutions and foreclosure loss and mitigation information, memberships, programs, products and services; offer and provide other credit and financial information, memberships, programs, products and services; and offer and provide access to automobile and consumer goods and services to you now or in the future.
We may use your personal and other information for general and customized market analysis and research for you, and for personalized marketing to you of information, memberships, products, programs, and services from us and from independent businesses.
We also use your personal and other information to administer our relationship with you, and to manage your relationship with us, including to contact you regarding these matters; facilitate your interactions and transactions with us including processing your applications, requests, orders, and payments; provide products and services to you; process and respond to your inquiries, requests, and other communications; provide you with information regarding us and our products and services, and related products and services offered by independent businesses; administer and facilitate your participation in contests and promotions offered by us; maintain, protect, and improve our products and services and offer new products and services; protect and enforce our legal rights, interests, and remedies; and to protect the business and operations of us and other independent businesses.
We 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 other websites and social media websites visited by users of our websites. Advertising vendors use cookies, web beacons, and tokens, which are unique identifiers of a web browser on a specific computer that are installed on the computer, when they access our website to display ads.
How We Disclose Personal Information?
We disclose your personal and other information for purposes relating to or arising from your relationship and transactions with us, as otherwise set out in this Privacy Statement, and as permitted by applicable law. We may disclose your personal and other information in accordance with the express or implied consent that you provide during your interactions and transactions with us.
If we refer you to an independent business for a proposed transaction, then we may disclose your personal information to facilitate that transaction. Once disclosed, however, we have no control over, or responsibility or liability for, the use, disclosure, or retention of the disclosed information by the independent business. The use, disclosure, and retention of the disclosed information by the independent business are not subject to this Privacy Statement.
We may disclose your personal information to suppliers and service providers to assist in the provision of information, products and services to you, and to provide services to us, including assistance with compliance: assist us in using your personal information as set out in this Privacy Statement and as permitted by applicable law.
We 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. We may disclose your personal information to government, law enforcement, national security agencies, other independent organizations, or other persons if we reasonably believe the disclosure is necessary or appropriate in connection with issues of public importance, or if we reasonably believe the disclosure is necessary or appropriate to protect and enforce our legal rights, interests, and remedies; protect the rights, interests, business, operations or customers of other parties, including to detect and prevent fraud and other illegal activities; or enforce any of the terms of use, terms of service, or other agreements that govern access to or use of any of our products or services. We have no control over, or responsibility or liability for, the use, disclosure or retention of your personal information by the government, law enforcement, security agencies, independent organizations, or other persons to whom we disclose the information in the foregoing circumstances. The use, disclosure, and retention of the disclosed information by those agencies, organizations or persons are not subject to this Privacy Statement.
We may disclose your personal information in connection with a proposed or actual business transaction in which we are involved such as a corporate amalgamation, reorganization, merger or acquisition, or the sale or transfer of some or all our business or assets. We will require the information recipient to agree to protect the privacy of your personal information in a manner that is consistent with this Privacy Statement and applicable law.
Retention of Personal Information
We and our service providers retain your personal and other information for the period reasonably necessary for the purposes set out or referenced in this Privacy Statement, and to comply with our legal obligations or enforce or protect our legal rights, for the length of the period required or as permitted by applicable law. We will securely dispose of your personal and other information when we are no longer reasonably required to retain the information for the purposes set out or referenced in this Privacy Statement.
Where Is Personal Information Processed, Transmitted, Stored, and Used?
We and our service providers may process, transmit, store, and use your personal and other information through data facilities, infrastructures, and services located in various countries including Canada, the United States of America, and countries in Europe or Asia. The personal information protection and privacy 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 and other information without notice. By providing your personal and other information to us and our service providers, you consent to the transfer and transmittal of your personal and other information to data facilities, infrastructures, and services located in other countries, and the processing and storage of your personal information at those facilities, infrastructures, and service locations.
Protection of Personal Information
We and our service providers use reasonable safeguards – including administrative, physical and technical security and safeguarding measures appropriate to the sensitivity of the personal and other information in our possession or under our control – to protect the information from unauthorized access, collection, use, disclosure, disposal or similar risks. Nevertheless, security risks cannot be entirely eliminated, and we cannot guarantee that your personal information will not be used, disclosed, or deleted in ways not otherwise described in this Privacy Statement. In the event that we become aware of a security breach, we will take all reasonable steps to mitigate the breach and will notify you.
Accuracy and Access to Personal Information
We rely on you to ensure that your personal and other information that you provide to us is as accurate, complete, and up-to-date as necessary for the purposes for which we use the personal information. You agree to promptly notify us of any changes to your personal and other information, using the procedures made available for that purpose, by contacting us. You may reasonably request access to your personal information collected by us, and information about our use, disclosure, and retention of that personal information by submitting a written request. Subject to applicable exceptions and limitations prescribed by 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. We 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.
Other Information
We create and collect non-personal information, including personal information that has been aggregated or otherwise depersonalized so that the information no longer relates to an identifiable individual. We 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 we will treat the combined information as personal information for the purposes of this Privacy Statement, for as long as the non-personal information is combined.
Independent Businesses
Websites and communications from us may include advertisements for products and services offered by independent businesses or contain links to websites, webpages, social media, and online platforms operated by independent businesses. We have no responsibility for, liability for, or control over those other websites, webpages, social media, and online services, the businesses themselves, their products or services, or the collection, use, disclosure, or retention of personal and other information by those businesses. This Privacy Statement does not apply to the collection, use, disclosure and retention of your personal information by independent businesses. If you have questions about how an independent business collects, uses, discloses, or retains personal information, please contact that business.
Disclaimers, Limitations, and Disputes
The agreements (including any subscription agreement, membership agreement, or terms of service or use for the website) that you accept when you apply, register for, order, or use our products or services or websites contain important provisions, including provisions disclaiming, limiting, or excluding the liability of us and other persons such as 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 the Privacy Statement, or the collection, use, disclosure, and retention of your personal and other information, and are of the same force and effect as if they had been reproduced directly in this Privacy Statement. Nothing in this Privacy Statement amends any of those other agreements.
Changes to this Privacy Statement
The company and our affiliates, partners, nominees, and third parties may change the Privacy Statement from time to time by posting a new version of this Privacy Statement on the website. Our collection, use, disclosure, and retention of your personal and other information will be governed by the latest version of this Privacy Statement in effect at the time. When we post modifications to the Privacy Statement, the revised Privacy Statement will be effective immediately on posting. Your continued dealings with us after the date of any change to this Privacy Statement signifies your consent and agreement to abide by and be bound by the collection, use, disclosure, and retention of your personal and other information as set out in the revised Privacy Statement. We encourage you to periodically review the Privacy Statement for the latest information on our privacy practices.
CANADIAN ANTI-SPAM LEGISLATION (CASL) POLICY
By checking the Privacy Statement and CASL Policy Box on our website and successfully submitting your application through our website, you are authorizing us and any third party lender who may provide financing to communicate with you via email, social media, text message, telephone, fax, or any other form of electronic method via computers, smartphones, mobile or handheld devices, or telephones. We may send messages to our applicants, clients, customers, and members in relation to our services, programs, programs, offers, and promotions or those of third parties, third party lenders, and service providers.
You are welcome to unsubscribe at any time by either clicking the “unsubscribe” button on any of our emails, by directly contacting us by phone, mail, or email, or by any other means specified in our website or a relevant agreement.
