SUBARU CANADA, INC. PERSONAL INFORMATION PRIVACY POLICY FOR CUSTOMERS, SUPPLIERS, DEALERS AND PARTNERS OUR PRIVACY COMMITMENT

Last revised: September 20, 2017

OUR PRIVACY COMMITMENT

Subaru Canada, Inc. ("Subaru") values its relationship with you, our existing or potential customers, suppliers, employment applicants, dealers and partners, and is committed to maintaining the security, confidentiality and privacy of your personal information. Subaru has developed a Personal Information Privacy Policy incorporating the principles set out below, to reflect its on-going commitment to you. Subaru has ensured that its Privacy Policy is in compliance with Canadian privacy laws which apply to the collection, use and disclosure of personal information.

SCOPE OF POLICY

"Personal Information" as used in this Privacy Policy means information about an identifiable individual. This Privacy Policy does not apply to the collection, use or disclosure of business contact information (for example the name, title, business address and telephone number of an employee of an organization), to Subaru's employees, or in part to certain publicly available information.

ACCOUNTABILITY

Accountability for Subaru's compliance with its Privacy Policy rests with Subaru's Privacy Officer, even though other individuals within Subaru may have responsibility for management of personal information or may be delegated to act on behalf of the Privacy Officer.

Subaru will be responsible for personal information in its possession or custody, and will also use reasonable contractual or other available means to provide a comparable level of protection when the information is being processed or managed by a third party on Subaru's behalf.

PURPOSES

In general, Subaru has collected, and will continue to collect, use and disclose personal information for purposes authorized or required by law, as well as for the following purposes:

  • to administer your transaction;
  • to provide to you with products and services related to your current and future vehicles;
  • to assist you to finance or lease vehicles;
  • to administer customer notification programs;
  • to evaluate your satisfaction with their products and services;
  • in accordance a consent you have provided us or our dealer on our behalf
  • to maintain accurate customer records to satisfy legal and industry-wide regulatory obligations
  • to make annual filings and reports with regulatory bodies, shareholders and creditors
  • to respond to your inquiries;
  • to distribute Six Star Review, The Magazine for Canadian Subaru Owners and similar Subaru magazines and publications
  • to permit carefully selected third party providers of products and services related to your current and future vehicles to provide their goods and services to you, such as roadside assistance providers or satellite radio providers
  • to permit Subaru, our dealers and/or carefully selected third parties to contact you by mail, email, text, cell/telephone, or other means of telecommunication to provide you with news, information, updates, advertising, and promotions about products and services that may be of interest to you
  • to analyse the operations of dealers, suppliers and business partners
  • to allow you to participate in Subaru vehicle test drives
  • to share some of your information under strictly limited and confidential circumstances with our affiliates, dealers, representatives, suppliers and Subaru business partners such as the Canadian Automobile Association (CAA) who assist us in providing products and services and allow us to more effectively carry on our business
  • to establish, administer and document training, development and educational requirements and programs
  • to establish, administer and document incentive programs
  • to evaluate potential suppliers and their staff, make decisions about entering into product and/or supply relationships with them, and to monitor, assess and address these relationships
  • to evaluate potential dealers and their staff, make decisions about entering into dealer relationships with them, and to monitor, assess and address these relationships
  • to evaluate potential partners and/or co-suppliers and their staff, make decisions about entering into relationships with them, and to monitor, assess and address these relationships
  • to implement and manage security programs and internal controls (including computer monitoring and video surveillance)
  • to protect Subaru, and its customers, suppliers, dealers and partners, from theft, fraud and similar risks
  • to assist dealers in carrying on their business and related products and services, such as warranty and non-warranty services for vehicles, vehicle parts, extended warranty arrangements and financing of vehicle purchases
  • if we engage a third party to provide services to us (such as marketing, IT or storage services)

WEBSITE

Automatically Collected Information

Like most commercial websites, when you visit Subaru's website we may automatically collect the following information:

  • technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
  • information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

Cookies, Pixels and Web Tracking Technologies

Our website uses cookies and pixels, which are industry standard technologies used by most major commercial websites.

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our website. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

Please note that third parties (including, for example, our third party business partners) may also use cookies or other web tracking technologies, over which we have no control.

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block cookies all or parts of our website may not function correctly and your experience on our website may be hindered.

Pixels (as known as web beacons/web bugs/javascript) are tiny graphics with a unique identifier that are used to track the online movements of web users, track what other web websites you visit (both before and after visiting our website), or to determine whether you have performed specific actions. Unlike cookies, which are stored on a user's computer hard drive, pixels are small graphics that are about the size of the period at the end of the sentence that are embedded invisibly on web pages or in HTML-based messages. When you access our website or open our messages, the pixels generate a notice of that action to us, or our third party business partners.

Use Made of the Information

We use the information collected through our website, cookies and pixels in the following ways:

  • to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • to improve our website to ensure that content is presented in the most effective manner for you and for your computer;
  • to allow you to participate in interactive features of our website, when you choose to do so;
  • as part of our efforts to keep our website safe and secure;
  • to deliver relevant messages and advertising to you, both on our website and the websites of our third party business partners; and
  • to measure or understand the effectiveness of messages and advertising we serve to you and others.

Disclosure of the Information

We may share the information collected through our website, cookies and pixels with selected third parties including:

  • Our suppliers and sub-contractors that provide technical and delivery services to us, for the performance of any contract we enter into with them.
  • Our third party business partners (such as social networks: Facebook, Instagram, Twitter and YouTube, advertising networks, analytics providers: Google, and search information providers: Google) that require the data to select and serve relevant messages and advertising to you and others. We do not disclose information about identifiable individuals to these business partners, but we may provide them with aggregated or anonymized information about our existing or potential customers or website visitors. We may also disclose to our business partners and use such aggregated or anonymized information to help us reach the kind of audience we want to target with our messages and advertising on our third party business partners’ websites. If you would like more information about our use of third party business partners to select and serve relevant messages and advertising to you and others or your options for opting-out of those activities, please contact Subaru’s Privacy Officer at the contact information at the end of this Privacy Policy.
  • Analytics and search engine providers that assist us in the improvement and optimization of our website.

Online Tracking and Advertising

If you would like more information about advertisers' use of tracking technologies to deliver targeted ads to you, or to opt-out of receiving targeted ads by advertising networks participating in certain opt-out programs, you can go to: https://youradchoices.ca/choices/

We also encourage you to check the privacy policies of social networks that you belong to and to adjust your advertising settings on those social networks with regard to targeted advertising delivered on those social networks, including by Subaru if the social network is our business partner.

Please be aware that, even if you are able to opt-out of certain kinds of ads, you will continue to receive non-targeted ads. Further, you may continue to receive targeted content and/or ads from parties that do not participate in the opt-out programs. Also, if your browsers are configured to reject cookies when you visit the opt-out page, or you subsequently erase your cookies, use a different device or web browser(s), or use a non-browser-based method of access, your opt-out may not, or may no longer, be effective. Subaru is not responsible for the effectiveness of, or compliance with, any third parties' opt-out options or programs or the accuracy of their statements regarding their programs.

CONSENT

The way in which Subaru obtains your consent to collecting, using or disclosing your personal information will vary depending upon its sensitivity and legal requirements. We may ask for your consent or our dealer may obtain a consent on our behalf. Your consent also may be implied or implicit through your conduct when it is reasonable and legally permissible for us to do so.

We will honour any specific consents you provide to us regarding the collection, use, and disclosure of your personal information. You may withdraw or change your consents at any time, subject to legal or contractual restrictions, by giving to Subaru reasonable notice. In appropriate cases, Subaru will inform individuals of any implications of withdrawing consent. Notwithstanding the foregoing, Subaru reserves the right to retain, collect, use, and disclose your personal information and to contact you where Subaru is legally required or permitted to do so.

Subaru will not, as a condition of the supply of services, require an individual to consent to the collection, use, or disclosure of personal information beyond that required to fulfil the specified purposes.

In certain circumstances as permitted or required by law, Subaru may collect, use or disclose personal information without the knowledge or consent of the individual. These circumstances include the following: to investigate a breach of an agreement or a contravention of a law; where collection or use is clearly in the interests of the individual and consent cannot be obtained in a timely way; for debt collection; to act in respect to an emergency that threatens an individual; or to comply with a subpoena, warrant or court order.

If you want to unsubscribe from Subaru and/or certain non-Subaru third parties contacting you by mail, email, text, cell/telephone, or other means of telecommunication to provide you with news, information, updates, advertising, and promotions about products and services that may be of interest to you, and/or correct your personal information, please click here privacy.mysubaru.ca

LIMITS FOR COLLECTING, USING AND DISCLOSING PERSONAL INFORMATION

Subaru will limit the amount and type of personal information collected to that which is necessary for the purposes of the collection.

Personal information will be retained only as long as necessary to fulfil the purposes of the collection or as required or permitted by law, and at the end of such time will be destroyed or made anonymous. Personal information which has been used to make a decision about an individual will be retained long enough (for at least one year after using it) to reasonably allow the individual access to the information after the decision, and long enough to exhaust any access request or a challenge an individual may bring under applicable privacy laws.

ACCESSS

All individuals generally have a right to access their personal information in Subaru's possession or custody. Upon receiving a written request (mail, e-mail or fax) addressed to Subaru's Privacy Officer clearly identifying the requested information with adequate identification of the requesting individual, Subaru will inform the individual of the existence, use, and disclosure of the personal information and give the individual access to that personal information. If Subaru is not able to provide a list of the organizations to which it may have actually disclosed the personal information, it will provide a list of organizations to which it may have disclosed the information.

Subaru will respond to an individual's written access request, with information in a form that is generally understandable, within a reasonable time (generally within 30 days) or will provide an explanation if additional time is required to fulfil the request. Subaru's response will typically be provided for a minimal handling fee which Subaru reserves the right to vary depending on the nature of the request and the amount of information involved. Subaru will inform the individual of the approximate cost to provide the response, and will provide the information upon receipt of payment.

Individuals can question the accuracy and completeness of their personal information and request that it be amended as appropriate. If an individual demonstrates in a reasonable manner the inaccuracy or incompleteness of their personal information, Subaru will amend the information as required. If a request is not resolved to the satisfaction of the individual, Subaru will record the substance of the unresolved request. Where appropriate, the amended information or the existence of the unresolved request will be transmitted to third parties having access to the information in question.

In some situations, Subaru may be permitted to refuse or not be able to provide access to certain personal information, and will upon request provide an explanation. Exceptions to the access right which are permitted or required by applicable privacy laws include: information that contains references to other individuals or contains confidential commercial information (where such information cannot be severed from the record); information collected in the course of investigating a breach of an agreement or in the course of a formal dispute resolution process; and information that is subject to solicitor-client privilege.

If you need to obtain a copy of the form to be used to make access requests to Subaru for your personal information which Subaru may hold, please click here: SCI Access Request Form

ACCURACY

Subaru will use reasonable efforts to ensure that the personal information it uses on an ongoing basis is accurate, complete and up-to-date as necessary for the purposes for which it is to be used, including information that is disclosed to third parties, and information that is used to make a decision about an individual.

SAFEGUARDS

Subaru protects the personal information it holds or controls, by establishing reasonable security arrangements against loss, theft, unauthorized access, use, disclosure, copying or modification. Subaru will make its employees aware of the importance of maintaining the confidentiality of personal information, and will exercise care in the disposal or destruction of personal information. Examples of safeguards include physical measures (such as locked filing cabinets and access cards), organizational measures (such as security clearances and restrictions on employee access to files and databases) and technological measures (such as passwords and firewalls).

TRANSMISSION AND PROCESSING OF YOUR INFORMATION

Subaru may transmit personal information outside of Canada, including to the United States, for processing by Subaru, its affiliates or third party service providers for some or all of the purposes described above. While outside of Canada, personal information may be accessible to law enforcement and national security authorities of the foreign jurisdiction. If you have questions about Subaru's policies and practices regarding the use of affiliates and service providers outside of Canada to collect, use, disclose, or store personal information, please direct them to Subaru's Privacy Officer at the contact information at the end of this Privacy Policy.

OPENNESS

Subaru will make the following readily available: general information concerning our Privacy Policy; how to gain access to your personal information; the type of personal information held by Subaru; a general account of the use and disclosure of the personal information; and how to contact our Privacy Officer.

CHANGES TO THIS PRIVACY POLICY

Since Subaru may review its policies and procedures, Subaru may change this Privacy Policy from time to time and the revised Privacy Policy will be effective on posting the revised Privacy Policy on our website with a note of the date the Privacy Policy was revised. It is therefore important that you review this Privacy Policy regularly.

CHALLENGING COMPLIANCE

Subaru will, on request, provide information regarding its procedure for addressing any complaints made with respect to Subaru's application of privacy laws. Subaru will investigate all written complaints, and if it finds a complaint to be justified, Subaru will take the appropriate measures, including, if necessary, amending our policies and practices.

Please direct any questions about the complaint procedure or any other aspect of this Privacy Policy to Subaru's Privacy Officer at:

Privacy Officer
Subaru Canada, Inc.
560 Suffolk Court
Mississauga, Ontario, L5R 4J7
e-mail at: privacy.mysubaru.ca
Telephone: 1-800-894-4212
Fax: 905-568-8087