Privacy Policy

1. How We Collect Personal Information:

Our dealership collects information online primarily to provide our visitors with a more relevant experience on our website. When doing so, we make reasonable efforts to avoid excessive or irrelevant collection of data. We collect information about you in the following ways.

For the most part, we collect personal information when you provide it directly to us. For example, when you enroll in one of our e-mail reminder services, request information, book a test drive, or request a quote. Our dealership maintains a strict "no-spam" policy. Subscribers to our e-mail services (or any other feature/service found on our website) will not receive unsolicited e-mail messages from us and may opt-out at any time.

Like many sites, we may automatically collect technical information anytime you visit our website including certain non-personally identifiable information regarding the way you use our website. See "Cookies and Targeted Advertising" to learn more.

Also, to help us better understand and respond to your needs and interests, we may collect information about you from third party sources. We will ask any provider of such information to confirm that the information may be disclosed to us in accordance with all applicable laws.

2. The Types of Personal Information We Collect:

Depending on how you use our website, our dealership may collect the following personal information about you:

• Contact information: If you create a user / customer account, or contact us, we may collect your name, home address, e-mail address, phone number, username and password. If you use your social media account to log in or interact with our website, we may collect your social media username.
• Vehicle information: Vehicle Identification Number (VIN), license plate number, make, model, year, colour, mileage, service history.
• Services information: If you book a test drive, request a quote, or other online Service, we will collect your contact information as well as the details of your requested Services, such as date and time of the Service.
• Demographic information: We may include demographic information, such as age or age range, gender, marital status, date of birth.
• Communication information: If you contact our dealership, including to make a request, submit a complaint or other type of communication, we will collect any information you provide to us (i.e. name, e-mail address, etc.) as well as the communication details.
• Marketing Preferences: When you enroll in one of our e-mail reminder services, request information, or use any of the other interactive portions of our website, we will collect your contact information and marketing preferences. This information may be used to provide you with information you've requested about our company, our products and our services, or to provide you with special notices. This data may also be used to tailor your experience on our website by providing content that is relevant to your interests and geographic region.
• Technical data: This information may include the type and version of your browser, your service provider, your IP address and the general geographic location associated with your IP address known as IP geolocation, any search engine you may have used to locate our website. We may use this information to help diagnose problems with our server, administer the website, and compile broad statistical data. In addition, we may collect certain navigational information about where you go on our website. This information enables us to determine which areas of the website are most frequently visited and helps us to tailor the website to the needs and interests of our online visitors. Such information is gathered by us in the aggregate and will not be associated with a specific individual without that individual's consent. See "Cookies and Targeted Advertising" to learn more.

3.How We Use Personal Information:

As outlined above, our dealership collects information online primarily to provide our visitors with a more relevant experience on our website.

In particular, our dealership may use personal information as follows:

• To create, administer and manage your user account.
• To process your requested Service.
• To respond to your request, complaint, feedback or other communication.
• To provide our customers with products and services related to their current and future vehicle needs.
• To understand our customers, their needs, preferences, and their satisfaction.
• To launch and administer our sales, incentives, contests and other promotions.
• To send you advertisements tailored to your interests, demographics and geographic region.
• To measure the effectiveness of our advertising.
• To operate our website, fix bugs and troubleshooting, improve functionality and user experience, analyze and understand how visitors use our website, Services and its functions, and enforce our Terms of Use.
• For the other purposes described in the "The Types of Personal Information We Collect" section above and in the "Cookies & Targeted Advertising" section below.
• For other purposes we may identify from time to time.
• As required or permitted by applicable law.

4. How We Share Personal Information:

Our dealership may share or disclose personal information as follows:

Subaru Canada, Inc. and Other Subaru Entities: As described above, we necessarily share your personal information with SCI, the distributor of Subaru brand vehicles in Canada, in order to provide you with Subaru vehicles, products and services and to ensure your entire Subaru experience, from start to finish, is seamless. Please review SCI's General Privacy Policy for a description of how SCI collects, uses and discloses personal information of Subaru customers and potential customers when you purchase or lease Subaru vehicles, purchase other Subaru products and services, and when you visit this website and SCI's websites and mobile apps. We may also share your personal information with other entities within the Subaru family for similar purposes.

• Dealer Dot Com, and other Cox Automotive Entities: We share your information with Dealer Dot Com, our website provider, who, in turn, may share your personal information with Cox Automotive Canada Company, its affiliates and/or subsidiaries. We may also share your personal information with other entities within Cox Automotive Canada Company for similar purposes.
• Business Partners: Our dealership may partner with select retailers and other companies at various times to provide expanded services to our website visitors. As part of such a relationship, we may share information with these companies such as the use of certain interactive website functions (i.e. the e-mail reminder service). Information provided by website visitors through the use of such interactive functions may be available to both our dealership and our partners. Also, we may share information with partners, such as promotional partners, in order to provide you with certain promotions.
• Service Providers / Agents: Our dealership may use third party service providers to perform certain functions on our behalf.
• Business Transfers: In the event that our dealership sells or transfers its business assets, consumer information may be one of the business assets transferred as part of the transaction. If substantially all of the assets of our dealership are acquired, consumer information may be transferred as part of the acquisition.
• Compliance with Law/Safety: We may disclose certain of your information when we, in good faith, believe disclosure is appropriate to comply with the law, a court order or a subpoena. We may also disclose your information to prevent or investigate a possible crime, such as fraud or identity theft; to protect the security of our website or Services; to enforce or apply our online Terms of Use or other agreements; or to protect our own rights or property or the rights, property or safety of our users or others.
• With Consent: Other than as set forth in this Privacy Policy, you will be notified when any personal information about you may be shared with third parties, and you will be given the opportunity to decline to share that information.

Other than as described above, we do not sell, rent, or trade consumer information without your consent.

5. Cookies & Targeted Advertising:

Like many websites and applications, our website may use cookies, etags, web beacons and similar technologies to automatically collect technical data from your computer or mobile device. This section explains the tools we use, the technical data we collect, and how we use it.

IP addresses. We may collect your IP address when you visit our website to help us diagnose problems, for system administration, to report aggregated information to our business partners, and to audit the use of our website. We do not normally link IP addresses to anything personally identifiable. In select circumstances, we may use IP addresses to help us identify you when we feel it is necessary (e.g. to enforce your compliance with our Terms of Use).

Cookies & similar technologies. Cookies are small files placed on your hard drive that assist us in providing you with a customized browsing experience. Our dealership uses cookies and similar technologies to provide you with the convenience of not having to re-enter information, such as user IDs and passwords, multiple times during your visits to our website. Cookies and similar technologies can also be utilized to help us provide you with information targeted to your interests, based upon your prior browsing on our website. The "help" section of the toolbar on most browsers will inform you on how to prevent your browser from accepting new cookies, how to have the browser notify you upon the receipt of a new cookie, or how to disable the use of cookies completely, as our website has been designed to take advantage of the use of cookies. If you disable or refuse cookies or block the use of other tracking technologies, some parts of this website may not be accessible or function properly and you may be required to re-enter any user IDs and passwords more frequently.

Online behavioural advertising. Online interest-based or targeted advertising means programs that decide which ads you might like to see based on non-sensitive information from your online activities, such as the actions you take when you visit this website as well as other websites. This data helps us and our ad partners understand your interests in order to display ads that you might enjoy. We also may participate in network advertising programs that display advertising about our Services, as well as other unaffiliated advertisers.

You can opt-out of network advertising programs that track your activities across multiple websites to deliver personalized advertising content to you. To opt-out, please visit the Digital Advertising Alliance of Canada Opt-Out Page: https://youradchoices.ca/en/tools.

We may also use third party advertising platforms, including Facebook, to promote interest-based advertisements to you, to better understand how you interact with those advertisements, and to develop new audiences for our products. We may do this by placing web tracking tools on our website or by converting the name, email address or phone number you have provided to us into a unique value that these platforms may then compare to a unique value created from information you provided to those platforms. This allows the platform to show you ads on that platform, and to find other users who may be interested in our products. Facebook uses cookies, web beacons and other storage technologies to serve you advertisements on and off Facebook's platform based upon your past visits to this website and elsewhere on the Internet. Please visit Facebook for information on Facebook's advertising privacy policies: https://www.facebook.com/about/privacy/. If you are a Facebook user and would like to opt-out, please go to the 'Ads' tab of your Facebook 'Settings & Privacy' page and adjust your Ad Settings, or use the opt-out features in the advertisement itself.

Please note that if you opt out of certain kinds of advertising, you will continue to receive non-personalized advertising and you may continue to receive personalized advertisements from parties that do not participate in the opt out programs.

6. Anonymized Data:

Our dealership may anonymize personal information into aggregated, non-personally identifiable data. Our dealership may use the anonymized data for our internal purposes, such as understanding trends, gaining insight into how users visit and interact with our website, and other internal purposes. The anonymized data may be shared with SCI, our business partners, service providers or other third parties. We reserve the right to use such anonymized data for any business purpose without further notice to you or your consent.

7. Security of Personal Information:

We use reasonable physical, administrative, and technical measures designed to secure your personal

information from accidental loss and from unauthorized access, use, modification, theft and disclosure.

Unfortunately, the transmission of information via the Internet and platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through the website. Any transmission of personal information is at your own risk.

The safety and security of your information also depends on you. Where we have given you (or you have chosen) a password for access to certain parts of our website, such as your own account, you are responsible for keeping it confidential. The personal data record created through your registration with our website can only be accessed with the unique password associated with that record. To protect the integrity of the information contained in this record, you should not disclose or otherwise reveal your password to third parties.

8. Storage/Transfers of Personal Information:

We store your personal information in Canada and transfer your personal information for processing and storage to countries outside of Canada including the U.S. We use contractual and other means to ensure the information is protected while in the foreign country however, your personal information may be still accessible to law enforcement agencies, government agencies, courts, and national security authorities of the foreign country. You expressly acknowledge and consent to our data activities outside of Canada.

9. Retaining Personal Information:

Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Further, we may retain anonymized and aggregated information that can no longer be associated with you.

10. Accuracy:

We will make reasonable efforts to ensure that the information we have about you is accurate, complete and up-to-date as necessary for our purposes (including information that we disclose to third parties) and to minimize the possibility that we use inaccurate information to make a decision about you.

11. Right of Access:

You have the right to request access to the information our dealership has about you and to request supporting information explaining how the personal information is used and disclosed. To do so, please contact us as set out below.

12. Right of Rectification:

You have the right to request that we correct inaccurate personal information about you. To do so, please contact us as set out below.

13. Right to Challenge Compliance:

You have the right to challenge our dealership's compliance with applicable privacy laws and we will investigate all written complaints. To do so, please contact us as set out below.

14. Your Choices:

We provide you with certain choices regarding your personal information subject to applicable privacy laws:

• Account updating. If our website provides you the opportunity to create a user account, you may be able to update or delete your account via your user profile settings.
• Tracking technologies. You can choose whether to allow the website to collect information through cookies or other tracking technologies by setting your computer or mobile device to refuse all or some cookies. If you disable or refuse cookies or block the use of other tracking technologies some parts of this website may not be accessible or may not function properly.
• Electronic marketing. Our website allows users to opt into receiving such communications at the point where personal information is requested, or through other means as identified. You may always opt-out of receiving promotional communications from our dealership using the opt-out mechanism included in the communication we send you.
• Online behavioural advertising. Our dealership and third parties using information to provide online interest-based or targeted advertising may provide you with additional choices about how they use your information or ways to choose not to have your information collected or used in this way. You can opt-out of several third party ad servers' and networks' cookies simultaneously by using an opt-out tool created by the Digital Advertising Alliance of Canada. Opting out of a network does not mean you will no longer receive advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns. See "Cookies & Targeted Advertising" for more options.

15. External Links:

Our website contains links to other sites. Our dealership is not responsible for the privacy practices or the content of such other sites. To help ensure the protection of your privacy, we recommend that you review the privacy policy of any site you visit.

16. Public Forums:

Our website may make chat rooms, forums, message boards, and/or news groups available to its users at various times. Please remember that, unless otherwise stated, any information that is disclosed in these areas becomes public information and you should exercise caution when deciding to disclose your personal information in these areas.

17. Contact Us:

If you have questions concerning this Privacy Policy, our use of service providers outside of Canada, or the practices of this website, you may contact us at: