PRIVACY POLICY

The Canadian Automobile Dealers Association ("CADA" or "we") is committed to maintaining the accuracy, security and privacy of personal information in accordance with applicable legislation. This privacy policy (the “Privacy Policy”) sets out how the CADA collects, uses and discloses personal information in connection with our Auto Career Start website located at www.autocareerstart.com (the "Website") or the use of the Services, as defined in our Terms of Use (the “Terms”) located at https://autocareerstart.com/terms.

Consent

BY SUBMITTING PERSONAL INFORMATION TO CADA, ITS SERVICE PROVIDERS, OR AGENTS, OR BY USING THE WEBSITE, YOU AGREE THAT THE CADA MAY COLLECT, USE AND DISCLOSE SUCH PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY AND AS PERMITTED OR REQUIRED BY LAW. Subject to legal and contractual requirements, you may refuse or withdraw your consent to certain identified purposes at any time by contacting the CADA Chief Privacy Officer at privacy@cada.ca or using the other contact information provided at the end of the Privacy Policy. If you refuse or withdraw your consent we may not be able to provide you or continue to provide you with certain services or information which may be of value to you. If you provide the CADA or our service providers and agents with personal information of another individual, you represent that you have all necessary authority and/or have obtained all necessary consent from such a person to enable us to collect, use and disclose such personal information for the purposes set forth in this privacy policy.

This Privacy Policy covers the following topics:

1. What personal information do we collect?
2. Why do we collect personal information and how do we use it?
3. To whom do we disclose your personal information?
4. Where do we store your personal information?
5. How may you obtain access to your personal information?
6. How do we protect your personal information?
7. Privacy and our Website and Services
8. Changes to the privacy policy
9. Further information

What Personal Information Do We Collect?

“Personal Information” means information about an identifiable individual. Not all information we collect identifies you or can be attributed as being identifiably about you. Similarly, we may aggregate your information with other information, or anonymize your information, in a way that it isn’t attributable as being identifiably about you. This Privacy Policy does not apply to restrict our collection, use or disclosure of such anonymous or aggregated information, which we refer to in this Privacy Policy as “Aggregated Information”.

In administering the Website, we collect the following types of Personal Information when you visit our Website or use our Services:
 

• User Support Information. We may collect Personal Information through your communications with our user support and outreach teams to respond to your inquiries, improve our Services and offer you the Services.

• Website Use Information. We automatically collect Personal Information as you visit and use the Website and Services in our server logs and through the use of Cookies and web beacons (or tracking pixels or similar technologies). This is described in more detail in the section below entitled “COOKIES AND BROWSING INFORMATION”.

Why Do We Collect Personal Information and How Do We Use It?
 

We use Personal Information for the following reasons:

• To ensure that content from the Website is presented in the most effective manner for you and for your computer or other device.
• To provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes.
• To notify you about changes to our Services and provide you with information that may be relevant to your use of the Services.
• To provide you with advertising for CADA and CADA-affiliated products or services (or other products and services that may be of interest to you) on other websites based on your use of the Website and other websites.
• To create Aggregated Information.
• For additional purposes that may be identified at or before the time that the Personal Information is collected, or that you subsequently consent to.
• Without limitation, we use Aggregated Information that we or our third party service providers produce for the following purposes:
• To better understand how users use the Website and Services to allow us to continually improve and expand our Services and Website.

To Whom Do We Disclose Your Personal Information?

From time to time, we may disclose your Personal Information to:

• vendors and service providers including organizations or individuals retained by the CADA to perform functions on its behalf such as marketing, surveying, data processing, document management, and office services;
• to regulatory agencies, insurers or others in connection with regulatory or other obligations of the CADA in its capacity as a national trade association representing new franchised Canadian automobile dealers;
• any third party or parties, where you consent to such disclosure or where disclosure is required or permitted by law;
• as permitted by, and to comply with, any foreign and domestic legal or regulatory requirements or provisions; and
• as consented to by you from time to time, including to fulfill any other purposes that are identified when the Personal Information is collected from you.

We do not rent, sell, or share Personal Information about you with other people or non-affiliated companies for their direct marketing purposes. We may share data collected through cookies and similar technology with third parties to allow the CADA to carry out advertisement retargeting as described under our uses of Personal Information above.

Where Do We Store Your Personal Information?

We take steps to ensure that your Personal Information is treated securely and in accordance with this Privacy Policy, including implementing reasonable industry standard practices. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us.

Your Personal Information is stored in locations and on servers located in Canada, controlled by the CADA, and located either at our offices or at the offices of our service providers. By submitting Personal Information, you agree to this storage and processing of your Personal Information. You acknowledge and agree that while your Personal Information is in a jurisdiction it may be accessed by the courts, law enforcement and national security authorities of that jurisdiction in accordance with the laws applicable in that jurisdiction.

If you are visiting the Website or using the Services from outside of Canada, please note that you are agreeing to the storage and processing of your information in Canada. By providing your information you consent to any transfer, including for storage and processing, in accordance with this Privacy Policy.

How You May Obtain Access to Your Personal Information

Upon your written request, subject to certain exceptions, the CADA will inform you of the existence, use, and disclosure of your Personal Information and will give you access to that information. Access requests should be sent to our Chief Privacy Officer using the contact information below.

There are a few instances where we may not be able to provide some of the personal information we hold, including:

• if it is subject to solicitor-client or litigation privilege;
• if it contains references to other individuals;
• if it cannot be disclosed for legal, security, or commercial proprietary reasons; or
• if it is prohibitively costly to provide.

Your Personal Information will be retained in accordance with the CADA’s policies and procedures for storing Personal Information; however you may request in writing to the address below for the earlier deletion of your Personal Information (where reasonably practical).

How Do We Protect Your Personal Information?

To help protect the confidentiality of your Personal Information, the CADA employs physical, administrative and technological safeguards appropriate to the sensitivity of your Personal Information. Where Personal Information is sent to a third party for processing we require that all Personal Information is kept secure. Please be aware though that, despite these efforts, no security measures are perfect and no systems are impenetrable. Particularly if you are using the password-protected areas of the Website, your privacy can be enhanced by taking care to use suitably strong passwords that others cannot guess, that are kept safe by you, and that are not re-used on other websites. Taking steps like avoiding dictionary words or proper names and adding extra character and punctuation marks can also help protect you. If you believe your password has been compromised, you should change it immediately.

Privacy and our Website and Services

When you browse our Website or use our Services, you should be aware of the following activities:

• Cookies - When you browse the Website, we may use a browser feature called a 'cookie' to collect information such as the type of Internet browser and operating system the visitor uses, the domain name of the website from which the visitor came, date and duration of the visit, number of visits, average time spent on our Website, pages viewed and number of cookies accumulated. A cookie is a small text file containing a unique identification number that identifies the visitor's browser, but not necessarily the visitor, to our computers each time our Website is visited. Unless a visitor specifically informs us (e.g. by registering for an event or sending us correspondence from our Website), we will not know who the individual visitors are. In addition to the identified purposes described in our Privacy Policy, we may use this Website information and share it with other organizations with whom we have a commercial relationship to measure the use of our Website, to improve the functionality and content of our Website and to facilitate usage by a visitor. Visitors can reset their browsers either to notify them when they have received a cookie or refuse to accept cookies. However, if a visitor refuses to accept cookies, he or she may not be able to use some of the features available on our Website.
• We use persistent cookies that only [CADA] and certain or our third party service providers can read and use, to identify the fact that you are a user of the Services and track the webpages you view and use. We are especially careful about the security and confidentiality of the information stored in persistent cookies. Users who disable their web browser’s ability to accept cookies will be able to browse our Website but may not be able to use all features of our Services.
• We also employ clear gifs, images, and scripts that help us better manage content on the Website.

• Online Communications - Visitors may voluntarily submit Personal Information to us for purposes such as asking a question, obtaining information, reviewing or downloading a publication, participating in a seminar or other event, and participating in contests and surveys. If you are known to the CADA as a registered user of an online service, we may combine and store Personal Information about your use of our Website and the online information you have provided with certain other online and offline information accessible to us.

• Electronic Communications - Occasionally, in compliance with Canada’s Anti-Spam Law (CASL), we may send electronic communications to you with information that may be useful to you, including information about the CADA and other third parties with whom we have a relationship. We will include instructions on how to unsubscribe and inform us of preferences if you decide you do not want to receive any future e-mails from the CADA. Such preferences may also be expressed by e-mailing our Chief Privacy Officer at privacy@cada.ca with your name and the electronic addresses you wish to have removed from our database. Please note, however, that in certain circumstances, the CADA may be required or empowered by law to send you certain important electronic messages notwithstanding an earlier unsubscribe request.

• Links - Our Website may contain links to other websites which are provided as a convenience only. Visitors are advised that other third party websites may have different privacy policies and practices than the CADA, and the CADA has no responsibility for such third party websites.
• Children’s Privacy - We do not knowingly collect, maintain, or use Personal Information from children under 13 years of age, and no part of our Website is directed to children under the age of 13. If you learn that your child has provided us with Personal Information without your consent, you may alert us at privacy@cada.ca. If we learn that we have collected any Personal Information from children under 13, we will promptly take steps to delete such information and terminate the child’s account.

Changes to this Privacy Policy

The CADA reserves the right to modify or supplement this Privacy Policy at any time. If we make a change to this Privacy Policy, we will post such changes on our Website and make such revised policy and changes available upon request to the CADA Chief Privacy Officer. However, the CADA will obtain the necessary consents required under applicable privacy laws if it seeks to collect, use or disclose your Personal Information for purposes other than those to which consent has been obtained unless otherwise required or permitted by law.

Further Information

The CADA’s Chief Privacy Officer oversees compliance with this Privacy Policy and applicable privacy laws. For information on the CADA's privacy practices or to inquire about the CADA’s collection, use or disclosure of your Personal Information, please contact the CADA Chief Privacy Officer at:

CADA, Chief Privacy Officer
123 Commerce Valley Drive East, Suite 303
Thornhill, ON  L3T 7W8

Email: privacy@cada.ca
Ph: 905-940-4959
Fax: 905-940-6870