NEW CAR DEALERS ASSOCIATION OF BC PRIVACY POLICY

The New Car Dealers Association of BC ("NCDABC" or "we") is committed to maintaining the accuracy, security and privacy of personal information in accordance with applicable legislation. This NCDABC Privacy Policy is a statement of principles and guidelines concerning the protection of personal information of our association members ("members"), new franchised British Columbian automobile dealers ("dealer members"), service providers and other individuals ("you").

Consent

BY SUBMITTING PERSONAL INFORMATION TO NCDABC OR ITS SERVICE PROVIDERS AND AGENTS, YOU AGREE THAT WE 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 of the identified purposes at any time by contacting the NCDABC Chief Privacy Officer. 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 NCDABC 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.

What Personal Information do we collect?

British Columbia Privacy Legislation generally defines "Personal Information" broadly as information about an identifiable individual. For the purposes of this policy, personal information means information about an identifiable individual as defined from time to time in applicable privacy legislation. Generally speaking, personal information does not include what is considered business contact information: your name, title or position, business address, telephone number, facsimile number, or information prepared by persons as part of their employment.. The types of personal information that NCDABC may collect about you include your name, home address, telephone number, personal email address, billing and account information, information about your business, and other information incidental to providing services to you and on behalf of new franchised British Columbian automobile dealers.

NCDABC may receive personal information from members or dealer members for the purpose of providing services to them and their customers. In these cases, NCDABC relies on the members or dealer members to ensure that such personal information is disclosed to NCDABC in accordance with applicable privacy legislation. Such personal information is used only for the purpose of providing the services in question.

We have a physical presence in British Columbia and may in the normal course of operations collect personal information through visits from the public, capture of video images on security cameras, telephone inquiries, or employment inquiries. This personal data, incidental to normal business administration, is not collected for a business purpose or shared with third parties except under exceptional circumstances as required by law.

Why do we collect your Personal Information?

In general, NCDABC collects, uses and discloses personal information about our members, dealer members, their customers, and others in order to provide our dealer members and members with association services to and on behalf of new franchised British Columbian automobile dealers. More specifically, we collect, use and disclose personal information for the following purposes:

• to fulfill the goals and mandates of a British Columbian trade association representing new franchised automobile dealers;
• to share Personal Information to and from third parties for the purposes of providing British Columbian trade association services to and on behalf of new franchised British Columbian Automobile dealers;
• to understand and respond to members, dealer members, suppliers, customers, and other third party needs and preferences, including to contact and communicate with such parties to conduct surveys, research, evaluations and trade shows;
• to develop, enhance or otherwise provide NCDABC products and services;
• to sell or otherwise provide products and services of third parties with whom NCDABC has a relationship;
• to distribute our Signals newsletter, other newsletters, association information and other materials to members and individuals on our mail and e-mail lists including via third parties mailing houses and e-mail service providers;
• to develop and manage NCDABC's association and operations;
• to detect and protect NCDABC and other third parties against error, negligence, breach of contract, fraud, theft, and other illegal activity and to audit compliance with NCDABC's policies and contractual obligations;
• to engage in business transactions including the purchase sale, lease, merger or amalgamation or any other type of acquisition, disposal or financing involving NCDABC;
• as permitted by and to comply with any foreign and domestic legal or regulatory requirements or provisions and;
• to provide information to our members in relation to their business;
• for any other purpose to which you consent.

To whom do we disclose your Personal Information?

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

• service providers including an organization or individual retained by NCDABC to perform functions on its behalf such as marketing, surveying, data processing, document management, and office services;
• a person who in the reasonable opinion of NCDABC is providing or seeking the information as your agent;
• to our insurers and to regulatory agencies, insurers or others in connection with regulatory or other obligations of NCDABC in its capacity as a national trade association representing new franchised British Columbian automobile dealers;
• to our members for the purposes of their business of marketing motor vehicles and/or other products and services;
• 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.

Where do we store your Personal Information?

Your Personal Information is stored in secured locations and on servers controlled by NCDABC, located either at our offices or at the offices of our service providers.

How may you obtain access to your Personal Information?

Upon your written request, subject to certain exceptions, NCDABC 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. We may charge a minimal fee to provide such personal information. 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

How do we protect your Personal Information?

To help protect the confidentiality of your Personal Information, NCDABC employs administrative and technological safeguards appropriate to the sensitivity of your Personal Information. Where Personal Information is sent to a third party for processing we ensure, through our contracts with them, that all Personal Information is kept secure. We operate secure data networks protected by industry standard firewall and password protection systems.

Privacy and our Website

• Cookies - When an individual visitor accesses the NCDABC 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 the website), we will delete any personal information which may be received without use and without delivery to third parties. 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 the 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.
• Online Communications - In order to provide our website visitors with a service or information, 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 NCDABC 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 we may have collected.
• E-Mail Communications - Occasionally, we may send e-mail communications to you with information that may be useful, including information about NCDABC and its members 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 NCDABC.
• 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 NCDABC, and NCDABC has no responsibility for such third party websites.

Changes to the Privacy Policy

NCDABC 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 NCDABC Chief Privacy Officer. However, NCDABC 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

NCDABC has appointed Tina Coleman as Chief Privacy Officer to oversee compliance with this Privacy Policy and applicable privacy laws. For information on NCDABC's privacy practices please contact the NCDABC Chief Privacy Officer at:

New Car Dealers Association of BC, Chief Privacy Officer, #70 - 10551 Shellbridge Way, Richmond BC, V6X 2W9, Email: tcoleman@newcardealers.ca, Phone: 604-214-9964, Fax: 604-214-9964.