TRADER CORPORATION PRIVACY POLICY

Trader Corporation (“Trader” or “us” or “we”) is committed to maintaining the confidentiality and protection of your Personal Information. This Privacy Policy explains how, and why Trader handles and protects your Personal Information. Personal Information is any information that allows a person to be directly or indirectly identified.

1. CONSENT

We rely on your consent to collect, use, retain, and share your Personal Information. This Privacy Policy outlines your options, where available, to refuse or withdraw your consent.

You agree to this Privacy Policy when you:

• apply for a product or service;
• use our websites and mobile app (‘‘the Sites”); and
• otherwise interact with us.

This Privacy Policy will apply:

• when you ask to begin a relationship with us;
• during the course of our relationship; and
• for a period of time after the end of our relationship.

We do not collect Personal Information from individuals under the age of 14 without the parent’s express and verified consent.

2. WHY AND HOW WE COLLECT YOUR PERSONAL INFORMATION

Beginning and maintaining a relationship with us

We need to collect certain Personal Information about you to provide our products and services. This may include your contact information, information about whether you are eligible for our products and services and records that reflect our overall relationship with you. We may also need other information depending on the product or service we are providing.

Information We Collect from You

The information we may collect includes: your name; your address; your telephone number; your email address; your Social Insurance Number (“SIN”) and your credit information.

Automated Information

We may through automated means collect and/or aggregate information regarding your use of the Sites such as:

• Your ISP or mobile carrier, and the type of handheld or mobile device that you used; and
• Your behavior while using our site, including the time you spend on portions of the site and how you interact with various aspects of the Sites.

3. HOW WE USE YOUR PERSONAL INFORMATION

We use your Personal Information to help us deliver and manage our products and services, and to administer our business. We may also use your Personal Information:

• When you express an interest in buying, selling, or trading in a car;
• Apply for credit with a dealer or one of our finance partners;
• To create listings and advertisements for any cars and other vehicles that you list for sale with us. These lists and advertisements may appear on the Sites and other websites, mobile applications, or services of third parties;
• To provide values and/or offers for cars that you would like to sell or trade in;
• To perform data analysis, including market and consumer research, trend analysis, demographic analysis, and financial analysis;
• To deliver content (including advertising) correlating to your interests and browsing and usage history, both within the Sites and on other websites and applications;
• To comply with applicable legal requirements and our policies; and
• To contact you via telephone, text, or chat. We will obtain your consent to contact you when and how required by law.

4. Our Use of Web Based Tools

We use certain technologies and tracking tools on our websites and apps to personalize your experience. For example, we use cookies, which are small identifiers sent from a web server that are stored on your device for the purpose of identifying your browser or storing information or settings in your browser. We also use pixels, beacons, and other technologies (“Web Based Tools”)

Essential Web Based Tools– We use Essential Web Based tools to make certain features available to you on our websites, to help ensure the security of your online browsing experience, to detect, prevent and investigate fraud and to collect information on how you use our websites.

Non-Essential Web Based Tools – We also use non-essential web-based tools to enhance your experience with personalized content. For example, remembering your language and similar settings and presenting offers that may be of interest to you. These tools also allow our third-party advertisers to personalize your online experience and present ads specific to your interests.

Combined Personal Information- We may pool your Personal Information such as your use of the Sites, your use of other websites, devices and mobile applications with other peoples’ Personal Information and Personal Information from our affiliates and other sources. You will not be identified in the combined information.

5. Online Advertising

We subscribe to Digital Advertising Alliance of Canada’s Self-Regulatory Principles for Online Behavioral Advertising. These principles promote consumer awareness and choice about how organizations use consumer information for Online Behavioral Advertising. You can learn more about the program by visiting the DAAC’s website here http://youradchoices.ca/.

Advertising Tracking – Trader and our third-party service providers may use Web Based Tools to deliver more relevant advertising based on which ads you interact with on our and third-party websites. We do not provide Personal Information that is directly associated with a specific person (such as name and address) to an advertising network when you interact with or view a customized advertisement.

6. Location Information

When you download or use the Sites, we may with your permission collect physical location information that allows us to locate a specific device (“Location Information”). We may use Location Information and provide it to third parties to provide you with relevant content and services, such as advertising, search results, dealers in the area, and to evaluate and improve the Sites.

You can decline to provide your Location Information or opt out by changing the location services settings on your mobile device. However, certain features may not function properly or at all as a result if you opt out.

7. OUR MOBILE APP

If you use a Trader mobile app, we may use your information to:

• operate the mobile app;
• help us understand how our users use our apps;
• authenticate you;
• keep the mobile app secure and prevent fraud; and
• improve our apps

We may advertise to you on third party apps. To do this, we may use your device identifier such as Apple’s Identifier for Advertiser (IDFA), or Google Advertising ID (AAID).

If you click on one of our ads on a third-party app, we may use Web Based tools such as your device.

App Permissions

When you download the Trader app on, the app may ask you to consent to some permissions the first time you download the app or when you access specific features in the app identifier. Some of these permissions relate to how we are going to use your information.

8. PROTECTING YOUR PERSONAL INFORMATION

Security Measures

We have internal policies and security standards to help protect our systems and your Personal information against unauthorized access and use. We retain your Personal Information only as long as we need it, and we only use it for the purposes that we explain to you. Our service providers and agents are contractually bound to keep your Personal Information confidential and must not use it for any unauthorized purpose. Our employees must also keep your Personal Information secure.

9. DISCLOSING YOUR PERSONAL INFORMATION

We may disclose your Personal Information to third parties, including to credit bureaus, and others. We disclose to these parties to help us deliver the products and services you request and to manage our business and risks. We do not sell or rent your Personal Information.

Credit Applications

If you apply for credit on the Sites with our dealers and lenders or any third party, you will need to provide your Personal Information, including your address, credit information and history, employment, and other financial information. We may share your application information with the dealership(s) you selected and our lenders/ financial partners so that they can process your application.

Corporate and Asset Transactions

If we sell all or substantially sell all of our business or sell or transfer all or a material part of our assets or are otherwise involved in a merger or transfer of all or a substantial part of our business, we may transfer all your Personal Information that we have collected and stored, to the party or parties involved in the transaction. We will require such providers to maintain your Personal Information confidentiality, to use it only for the purposes of the transaction and to safely destroy it once the transaction fails or when its purpose is fulfilled.
We may also disclose your Personal Information to:

Buyers, Sellers, Dealers and Manufacturers. Personal Information and Data Technologies may be shared with lenders, dealers and manufacturers, and their agents and third-party service providers, who will use that Information in accordance with their own privacy policies.

Employees. Your Personal Information is accessible to our officers and employees who must access it to make the use provided for in this Policy and with which they must abide.

Other

• Protect or defend our interests and the legal rights or property of Trader;
• Protect the rights, interests, safety, and security of users of the Sites or members of the public;
• Protect against fraud or for risk management purposes; or
• Comply with prudent legal practice as we may determine, and applicable law or legal process.

10. RETAINING AND DESTROYING YOUR PERSONAL INFORMATION

We retain your Personal Information only as long as we need it for the purposes, we collected it. Our Document Retention and Destruction Policy helps us determine us determine the length of time it should be retained. The length of time will vary and depends upon the product or service, the sensitivity of the information, and the purposes for which we use it. We may retain your information after the end of your relationship with us.

For example, we may continue to need your information:

• for legal or regulatory purposes;
• to respond to issues that may arise at a later date;
• to support fraud prevention organizations and other risk assessments; and
• for security purposes

When we no longer need your Personal Information for these purposes we may securely destroy, delete, or erase it. We may also convert it to an anonymous form.

11. YOUR RIGHT TO ACCESS AND CORRECT YOUR PERSONAL INFORMATION

Accessing Your Personal Information

Upon request, we will give you access to the information we retain about you. If the information you want concerns any decisions we made about your product or service, we will tell you about the reasons for those decisions unless otherwise prohibited by law. If we relied on information from a third party, such as a credit bureau, to make the decision, we will, where the law allows, provide you with the name and address of that third party.

Please note that we will not be able to provide information about you from our records that contain references to other persons, is subject to legal privilege, contains confidential information proprietary to Trader, relates to an internal investigation, risk assessment or violation of law, or that cannot be disclosed for other legal reasons.

Correcting Your Personal Information

We make reasonable efforts to keep your Personal Information accurate and up to date. If your information changes, please notify us immediately so that we can make the necessary changes.

Automated Decision Making

We use various technology tools to help us serve and communicate with you and to anticipate your needs. Sometimes, the tools allow us to make decisions about you in real time because the process is fully automated. When this occurs, we may notify you in advance of the decision, for example, in the application process. We will also tell you how you can contact us to learn more about the automated decision process.

12. WITHDRAWAL OF CONSENT

You may change or withdraw your consent to the collection, use and disclosure of your Personal Information at any time, subject to reasonable notice, by contacting our Privacy Officer, even though that might impact your ability to register or receive a particular product or service.

If you do not want to receive marketing email from us, you can follow the unsubscribe link provided in those emails.

If you do not want to receive interest-based advertisements, you can opt out.

You have a number of choices regarding certain Data Technologies. Most web browsers automatically accept cookies, but you can usually modify your browser’s setting to decline cookies if you prefer. You may also render some web beacons unusable by rejecting their associated cookies and disable or delete similar data used by browser add-ons, by changing the add-on’s settings or the website of the technology provider. If you choose to decline cookies or similar technologies, certain features may not function properly or at all. You may be able to adjust the use of advertising identifiers on mobile devices through the settings on your device. Finally, if you do not want to use a uniquely generated telephone number, you may choose not to call us.

13. DE-IDENTIFICATION AND ANALYTICS

We may de-identify or anonymize your Personal Information by removing identifiable information such as your name, address, date of birth and account numbers to use it for serious and legitimate purposes. It may be aggregated and used for internal business purposes such as analytics and reporting, developing, and improving our products and services, understanding, and predicting client needs and preferences, preventing and detecting fraud, identifying trends like purchasing patterns, fraud trends, or enhancing our marketing.

14. EXTERNAL LINKS

Trader’s Sites include hyperlinks to external websites operated by third parties. We do not have any control over how they collect, use, or disclose Personal Information. Please read the third party’s privacy policy to learn about its information and privacy practices before you provide any Personal Information.

15. PRIVACY OFFICER CONTACT INFORMATION

If you have any questions regarding this Privacy Policy, or if you wish to access or correct your Personal Information, please contact the Privacy Officer.

Email: privacy.officer@trader.ca
Mail: Privacy Officer
405 The West Mall, Suite 110
Etobicoke, ON
M9C 5J1