OUR COMMITMENT TO PRIVACY
TRADER , is committed to protecting the privacy and confidentiality of personal information. Our collection, use, and disclosure of personal information are governed by the Personal Information Protection and Electronic Documents Act (“PIPEDA”), Act Respecting the Protection of Personal Information in the Private Sector (“Quebec Law 25”), Canadian Anti-Spam Legislation (“CASL”), and other applicable provincial laws of similar effect. This Privacy Policy explains how we handle personal information collected through the Website, related applications (including mobile apps), and certain third-party websites accessible from the Website, treating such information as if obtained directly through the Website.
Designed specifically for business-to-business (“B2B”) relationships, this Privacy Policy outlines data handling practices within TRADER’s Financial Technology and Automotive Retail Marketing divisions. This policy is distinct from our Business-to-Consumer (B2C) Privacy Policy, reflecting our commitment to regulatory compliance and privacy protection in all data interactions with our business partners and consumers. Note that external websites linked from the Website have their own privacy policies, and we recommend reviewing those for information handling practices. TRADER assumes no liability for damages resulting from use of linked third-party websites.
If you have any questions or concerns related to this Privacy Policy or your personal information, please contact our Privacy Officer here:
Email:
privacy.officer [at] trader.ca
Mail:
Privacy Officer
405 The West Mall, Suite 110
Etobicoke, ON M9C 5J1
Telephone:
416-784-5200
By using the Website, you consent to the collection, use, storage and disclosure of this information as described in this Privacy Policy. If you do not, or cannot consent to these terms, you cannot use the Website.
GENERAL DEFINITIONS
“TRADER, we, us, our” means TRADER Corporation (a company with offices at 405 The West Mall, Suite 110, Etobicoke, Ontario, Canada, M9C 5J1) and its subsidiary, affiliated and successor companies. Click here for more information: www.tradercorporation.com/our-brands
The “Website” means the TRADER website accessible at go.trader.ca and any associated or co-branded features, applications, services or websites provided to you by TRADER.
The “Privacy Policy” means this privacy policy, including amendments, modifications, and additions.
1. SCOPE AND APPLICATION
This Privacy Policy applies to all data exchanged, collected, and processed during our B2B operations, including financial services, automotive retail marketing, and other commercial activities. It is relevant to our clients, suppliers, service providers, and other business partners with whom we engage under contractual agreements.
Where necessary, additional contractual agreements such as Non-Disclosure Agreements (“NDA”s), Data Sharing Agreements, and Security Addendums may be required to ensure the confidentiality and security of data shared for both B2B and B2C customers.
2. DATA COLLECTION
We collect and process business-related data to facilitate our Financial Technology and Automotive Retail Marketing, including:
- Business Contact Information: Names, business titles, email addresses, phone numbers, and office addresses of our clients’ representatives.
- Operational Data: Information required to provide and support our services, such as account details, transactional records, and marketing information.
- Technical and Usage Data: Data on interactions with our systems, websites, and applications, which may include IP addresses, device information, and usage patterns, as permitted by applicable regulations.
Personal data obtained in a business context (e.g., business email addresses and phone numbers) is handled according to the principles set out in PIPEDA, Quebec Law 25, CASL and our internal policies related to Data Privacy and Governance.
3. PURPOSE OF DATA COLLECTION
TRADER collects personal information for specific, limited purposes. Personal information is collected by fair and lawful means through the Website.
The data we collect is used for the following purposes:
- Service Delivery: To facilitate the provision of financial and automotive marketing services.
- Account Management: For account setup, management, and support.
- Compliance and Auditing: To meet legal, regulatory, and compliance obligations.
- Security and Fraud Prevention: To protect against fraud, unauthorized access, and other security risks.
- Marketing Communications: To provide information about our products and services, as permitted under CASL and other applicable laws.
4. COMPLIANCE WITH CASL AND MARKETING PRACTISES
In line with CASL, we ensure that all marketing communications are consent-based or fall within the permissible exceptions. Consent can be withdrawn at any time by clicking the unsubscribe link provided in all marketing offers, emailing marketing@trader.ca or by contacting our Privacy Officer at privacy.officer@trader.ca . We process unsubscribe requests promptly and document this process for auditing purposes.
TRADER adheres to the requirements of CASL and, in connection therewith, tracks consent choices and dates within its internal customer and prospect databases and makes every possible attempt to ensure only those who have provided express consent are targeted with sales and/or marketing related messages through commercial electronic messages. In addition, TRADER reserves the right to disclose your personal information as required by law and when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order or legal process served on the Websites, enforce or apply this Privacy Policy, or protect the rights, property or safety of the Website, its users or others. TRADER may also disclose your personal information to parties connected with the contemplated or actual financing, insuring, sale, assignment or other disposal of all or part of our business or assets, including for the purposes of determining whether to proceed or continue with such transaction or business relationship or fulfilling any records or other reporting requirements to such parties. We will require such parties to treat your personal information in accordance with this Privacy.
5. DATA TRACKING AND COOKIES
We use certain technologies and tracking tools on our websites and apps to personalize your experience. For example, we use cookies, which are 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.
6. DATA SHARING AND DISCLOSURE
We may share data with third parties in limited circumstances, including:
- Service Providers: Third-party vendors that support our operations, such as IT services, payment processors, or marketing platforms. Service providers must comply with our data privacy/protection standards and, where required, enter into Data Sharing Agreements and NDAs.
- Legal and Regulatory Authorities: As required by law, we may disclose data to regulatory agencies, law enforcement, or government authorities.
- Corporate Transactions: If we sell all or substantially 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.
All data-sharing agreements mandate the use of industry-standard encryption protocols and security measures to protect data during transfer and storage.
7. DATA SECURITY AND PROTECTION
We are committed to safeguarding data through comprehensive security measures, including:
- Encryption: Data is encrypted in transit and at rest using industry-standard protocols to prevent unauthorized access.
- Access Controls: Restricted access is enforced, limiting data access only to authorized personnel on a need-to-know basis.
- Regular Audits and Monitoring: Security practices are reviewed regularly to ensure compliance with regulatory requirements, including CASL, Quebec Law 25 and PIPEDA.
- Data Minimization: Only data necessary for the stated purposes is collected and retained, with retention periods aligning with regulatory and contractual requirements.
While we have the above data security policies and practices in place and use our best efforts to safeguard your personal information from unauthorized access, use or disclosure, we cannot be held liable in the event of unauthorized access to or inadvertent disclosure of any personal information.
8. DATA RETENTION AND DISPOSAL
Data is retained only for as long as necessary to fulfill the purposes outlined in this Privacy Policy or as required by law or contractual obligations. When data is no longer needed, it is securely disposed of in compliance with data protection standards.
- Backup and Restoration: Regular backups are conducted to ensure business continuity. Backup data is also encrypted and stored securely.
- Retention Policies: Specific retention periods are defined based on data type, regulatory requirements, and business needs.
9. CROSS-BORDER DATA TRANSFERS
Where business data is transferred outside of Canada, we ensure that it is protected by adequate safeguards, such as contractual obligations with third-party service providers, to maintain data security and regulatory compliance. Additional protections are applied as required under Quebec Law 25 for transfers involving Quebec residents’ data.
10. CLIENTS RIGHTS AND RESPONSIBILITIES
Our business clients are responsible for providing accurate, up-to-date information and ensuring their representatives are informed about data collection and sharing practices.
As part of our commitment to transparency, clients have the right to:
- Access: Request a copy of the information about the data we collect and process.
- Portability: Request and receive your personal information in a structured and commonly used technological form.
- Correction: Request corrections to any inaccuracies in the data.
- Objection: Object to certain data processing practices, where applicable.
Requests to exercise these rights permitted under PIPEDA and Quebec Law 25 can be processed by contacting our Privacy Officer.
11. DATA BREACH NOTIFICATION
In the event of a data breach involving personal or sensitive business information, TRADER will promptly assess the situation and determine the risk of harm. If the breach poses a significant risk, we will notify affected business clients without undue delay. Notification will include the nature and scope of the breach, the type of data involved, steps taken to mitigate potential harm, and recommendations for further protective measures. TRADER is committed to complying with all legal and regulatory obligations regarding data breach notifications, as outlined by PIPEDA, Quebec Law 25, and other applicable privacy laws.
12. CHANGES TO THIS POLICY
We reserve the right to update this Privacy Policy to reflect changes in our practices, regulatory updates, or advancements in technology. Clients will be notified of significant updates and may review the revised policy on our website or through direct communications.
13. OUR PRIVACY OFFICER
We have appointed a Privacy Officer to oversee compliance with this Privacy Policy. The contact information for our Privacy Officer is as follows:
Email:
privacy.officer [at] trader.ca
Mail:
Privacy Officer
405 The West Mall, Suite 110
Etobicoke, ON M9C 5J1
Inquiries related to this Privacy Policy or concerns relating to the collection, disclosure, accuracy, use or retention of information relating to you should be directed to the Privacy Officer. Our Privacy Officer also welcomes comments and suggestions for improvement to this Privacy Policy and to our privacy practices. We may not be able to implement every suggestion, but we are interested, and we are listening.
Last Updated: November 15, 2024
