PROTECTION OF YOUR INFORMATION
Application and Scope
Definition of Personal Information
Collection and Use of Personal Information
We collect most of our information about you directly from you, with your consent when required by law. For example, when you take a test drive, online request an appointment or vehicle quote, purchase or lease a vehicle, or service your vehicle, Stratford Motor Products will collect information about you. We may also conduct contests, quizzes, surveys, promotions and offer several forms of personalized services such as vehicle warranty, servicing and maintenance and OnStar services, in respect of which you may be requested to provide personal information, such as name, mailing address, telephone number, email address, age and other information that may be required to provide or administer these services or promotions.
[We may also obtain personal information about you from third parties, with your consent. For example, for credit evaluation purposes, we may need to determine your creditworthiness through contact with an independent credit reporting agency.]
Stratford Motor Products generally collects personal information from or about its customers and other individuals with whom it deals, and thereafter uses it, for the following purposes:
- to establish, develop and preserve its business relationship respectively with its customers and other individuals with whom it deals;
- to create, establish and administer customers’ accounts and to respond to customer or supplier inquiries;
- to provide the products or services that it offers, or receive the products or services that it requests, and ensure that all related transactions are supported and implemented;
- to authenticate the identity and preserve the privacy of customers contacting Stratford Motor Products by telephone, electronic means or otherwise;
- to conduct market analysis, as well as for internal training and quality assurance purposes;
- [as necessary, to establish or verify the credit of persons that use, or intend to purchase, one or more of the products or services offered by Stratford Motor Products];
- to manage its General Motors Stratford Motor Products business and ensure the efficiency, reliability and security of its systems and networks;
- to meet legal and regulatory requirements and allow %DEALER_NAME % to meet contractual requirements relating to the products and services provided to customers;
- to ensure its records are accurate and to protect customers and Stratford Motor Products from error and fraud;
- to understand and assess the interests, wants and changing needs of customers with a view to improving its products and services and developing new ones;
- to provide personalized products and services as well as product recommendations to customers; and
- subject to our customers’ Right to Withdraw Consent, to conduct surveys on the quality of our products, services or customer service or to provide our customers with offers for additional products and services that we feel may be of interest to our customers or that we believe meet our customers’ changing needs.
- If you have applied for employment with Stratford Motor Products, the personal information submitted with your job application will be used for recruitment and other customary human resources purposes. For example, we may send you information about new job opportunities within Stratford Motor Products as well as other career development resources.
Stratford Motor Products obtains consent from the individuals concerned for the collection, use or disclosure of personal information through various means: verbally or through written documents, including agreements, forms including vehicle purchase/leasing forms and repair orders, welcome kits as well as printed or electronic communications. The form of consent sought by Stratford Motor Products will vary according to the sensitivity of the personal information, the reasonable expectations of the individuals and any requirements or standards established by law.
- In certain circumstances, personal information may be collected, used or disclosed without consent. These exceptional circumstances may include:
- where it is clearly in the interest of the individual and consent cannot be obtained in a timely way, such as in emergencies, where the life, health or safety of the individual is threatened, or where legal, medical or security reasons make it impossible or impractical to obtain consent;
- when information is being collected, used or shared for the detection, prevention of or remediation to, the breach of an agreement, fraud or other illegal activity, and the collection of consent might defeat the purpose of collecting the information;
- to collect a debt; and
- to comply with a subpoena, warrant or other court order, or as may be otherwise required or authorized by law or by any regulatory bodies having jurisdiction.
Right to Withdraw Consent
Consent may be withdrawn at any time, subject to legal or contractual restrictions and reasonable notice; however, without such consent, Stratford Motor Products may be limited in the services or products it is able to provide customers. You may also withdraw your consent as follows:
Mail marketing, Telephone marketing and Quality control communications.
You may decide that you prefer Stratford Motor Products not to use your personal information to promote new and/or additional products and services which may be of interest to you and refuse further Stratford Motor Products contact by mail or telephone for marketing purposes or by email or telephone for quality control purposes. If this is the case, you may advise us by contacting customer service or contacting us using the information detailed in the How to Contact Us section below.
Commercial Electronic Communications.
You can always limit the communications that Stratford Motor Products sends to you. To opt out of commercial emails, simply click the link labeled ‘unsubscribe’ or ‘opt out’ at the bottom of any commercial electronic communication we send you. Please note that even if you opt out of promotional communications, we may still need to contact you with important information about your account or for other purposes as may be permitted or required under applicable laws. If you have any questions about your choices or if you need any assistance with opting out, please contact us using the contact information detailed in the How to Contact Us section below.
Sharing of Personal Information
Third party or affiliated service providers.
We may hire service providers, which may be affiliates, to perform services on our behalf. This may include, without limitation, a person or an organization retained by Stratford Motor Products to perform work on its behalf. We provide them with a limited amount of information which is necessary in order for them to provide the services required. They are prohibited from using the information for purposes other than to facilitate and carry out the services they have been engaged to provide. These service providers are not permitted to disclose this information to others.
As permitted or required by law.
From time to time, Stratford Motor Products may be compelled to disclose personal information in response to a law, regulation, court order, subpoena, valid demand, search warrant, government investigation or other legally valid request or inquiry. We may also disclose information to our accountants, auditors, agents and lawyers in connection with the enforcement or protection of our legal rights. We also reserve the right to report to law enforcement agencies any activities that we, in good faith, believe to be unlawful or to law enforcement and emergency services providers, in an emergency or where required or permitted by law. We may release certain personal information when we have reasonable grounds to believe that such release is reasonably necessary to protect the rights, property and safety of others and ourselves, in accordance with or as authorized by law.
[Stratford Motor Products TO DETERMINE WHAT APPLIES TO Stratford Motor Products SHIP ONLINE ACTIVITY]
Stratford Motor Products generally collects and uses personal information from or about its website visitors and users as follows:
- Information you provide. In many cases, we collect personal information directly from you when you visit or use our website. For instance, we may collect the following types of information:
Requests for Product and/or Service.
- Technical information. When you visit our website, we may use electronic means such as cookies to collect technical information. This information may include information about your visit to our website, including the IP address of your computer and which browser you used to view our website, your operating system, resolution of screen, location, language settings in browsers, the site you came from, keywords searched (if arriving from a search engine), the number of page views, information you entered, advertisements you have seen, etc. This data is used to measure and improve the effectiveness of our website or enhance the experience for our customers. For instance, it may be used to ensure that the products advertised on our website are available in your area or that we are not showing you the same ads repeatedly. We treat this information as personal information when it is associated with your account or contact information. We also collect and use the following information when you visit and/or interact with us on our website:
We use Google Analytics which allows us to see information on user website activities including, but not limited to, page views, source and time spent on our website. This information is depersonalized and is displayed as numbers, meaning that it cannot be tracked back to individuals. You may opt out of our use of Google Analytics by visiting the Google Analytics opt out page.
We use Google AdWords Remarketing to advertise Stratford Motor Products across the Internet and to advertise on third party websites (including Google) to previous visitors to our website. AdWords remarketing will display ads to you based on what parts of the Stratford Motor Products website you have viewed by placing a cookie on your web browser. It could mean that we advertise to previous visitors who haven’t completed a task on our site or this could be in the form of an advertisement on the Google search results page, or a site in the Google Display Network. This cookie does not in any way identify you or give access to your computer or mobile device. The cookie is only used to indicate to other websites that you have visited a particular page on our website, so that they may show you ads relating to that page. If you do not wish to participate in our Google AdWords Remarketing, you can opt out by visiting Google’s Ads Preferences Manager].
Stratford Motor Products does not allow third-party cookies on its website for purposes of delivering third parties’ advertising based on preferences or interests known or inferred from the data collected for advertising purposes (often referred to as Online Behavioural Advertising or OBA).]
Your Choice with Cookies.
Privacy Policies of Third Parties.
Personal Information Outside of Canada
In some cases, personal information that we manage may be transferred, processed and stored outside Canada, and therefore may be available to government authorities under lawful orders and laws applicable outside of Canada. Stratford Motor Products will strive to protect personal information disclosed to third parties by contractual agreements requiring that those third parties adhere to confidentiality and security procedures and protections that are, at a minimum, equivalent to those employed by Stratford Motor Products itself.
Security of Personal Information
We will use reasonable security measures to protect your personal information against unauthorized access. Stratford Motor Products has implemented security measures that contain administrative, technical and physical controls that are designed to safeguard your personal information.
Personal information will be retained only as long as necessary for the fulfilment of the purposes for which it was collected and for which consent was received, unless otherwise required or permitted by law. Personal information that is no longer required to fulfil the identified purposes or for a purpose required or permitted by law, will be destroyed, erased or made anonymous. Stratford Motor Products has developed and implemented retention procedures, and will ensure destruction of personal information in a method that prevents improper access.
Access and Correction
Stratford Motor Products respects your right to access and correct your personal information. If you need assistance updating your personal information, please contact us using the contact information detailed in the How to Contact Us section below.
How to Contact Us
STRATFORD MOTOR PRODUCTS (1984) LIMITED
At Stratford Motor Products (1984) Limited (” SMP””) we respect your privacy and value our relationship with you. Your personal information will be protected, and unless we advise you in advance, will be used only by SMP, our affiliates and service suppliers (only to provide services). Our goal is to enhance your product and service experience with us. We may have collected or from time to time, may collect personal information about you that will be used for the following purposes:
- Meeting safety, security, legal and regulatory requirements;
- Providing you with general marketing, product, service and business partner information and offers;
- Conducting market analysis;
- Maintaining the accuracy of our records to respond to your inquiries and provide you with warranty or other customer service communications
- Satisfying other reasonable, legitimate business interests (such as collecting outstanding debts).
For the purposes set out in this privacy statement, SMP or one of its affiliates or an unaffiliated service provider may process, store, and/or otherwise use your personal information outside of the province in which you reside and/or outside of Canada, and under the laws of those other jurisdictions, in certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other provinces or foreign jurisdictions may be entitled to access your personal information. If you do not wish to receive notice of special offers or other marketing information, or if you would like to receive only certain types of communications from us, please let us know.
WHAT INFORMATION ABOUT ME IS COLLECTED BY SMP AND HOW IS IT USED?
i. Personal Information that SMP May Collect About You
SMP collects personal information about you that is reasonably necessary for the purposes described above. We may collect this information directly from you or our website, affiliates, service providers, business partners, and other sources that compile lists of potential vehicle purchasers, always with your consent when required by law.
For example, when you take a test drive, purchase or lease a vehicle, or service your vehicle, SMP will collect information about you that may be shared with GM Canada for the above stated purposes. SMP also conducts contests, quizzes, surveys, promotions and offers several forms of personalized services such as vehicle warranty, servicing and maintenance and OnStar services, in respect of which you may be requested to provide personal information, such as name, mailing address, telephone number, e-mail address, age and other information that may be required to provide or administer these services or promotions.
SMP has arrangements with certain financial organizations who offer financing for the purchase or lease of GM vehicles. These arrangements may provide for the sharing, with your consent, of personal information that you disclose as part of the credit application process and/or personal information found in the related credit decision.
During normal website usage, you can visit our site without communicating any personal information. However, to make use of certain features on our site, such as contests, quizzes, promotions, personalized services, or online appointments users may need to register with the SMP site. As part of this voluntary registration, SMP may request contact and eligibility information such as name, mailing address, telephone number, e-mail address, age and other data required for operating these services or promotions.
As described in Section 1(i) above, we may also ask you to provide additional personal information. We use this information as described in our list of purposes set out above. Again, the more information you volunteer, and the more accurate it is, the better we are able to customize and improve your experience with SMP.
You should be aware that when you share personal information in public areas of our website, such as chat rooms or bulletin boards, this information might be seen and used by others. We urge you to exercise good judgment when sharing personal information in these forums.
We may use web beacons (sometimes called pixel tags or GIFS) to help us track usage of our website and the success of our electronic communications and advertisements. For example, web beacons may be used to tell us whether a web page has been viewed or whether e-mail messages have been opened and acted upon by collecting information such as when an email message is opened, how many times an email message is forwarded, the type of software, device, operating system and browser used to deliver the email and whether a link contained within the email message has been “clicked”.
We may use one or more third party service suppliers to deliver functionality available within our website, to report to SMP on page views and actions taken by users who visit our website, including users who link to our website by clicking on a SMP ad on a third party website, and to capture aggregated and anonymous information used for data analytics.
INTEREST BASED ADVERTISING
SMP may use third party display advertising services to serve our advertisements on other websites. Providers of these services may place cookies or use other tracking tools on your computer, including cookies set through and tracking tools facilitated by our website, and may collect certain information about your visits to our website and other websites. This information may include browser type, IP address, web activity and time of day, and may be used to make predictions about your preferences and to display advertisements across the Internet tailored to your apparent interests. This practice is commonly referred to as “Interest Based Advertising” or “Online Behavioural Advertising”.
Opting Out of Receiving Interest Based Advertising
You can elect to opt out of Interest Based Advertising from many third party advertisers directly on their websites or through the opt out made available by the Network Advertising Initiative and Digital Advertising Alliance. These industry alliances make opting out of receiving Interest Based Advertising easier by providing a single location to opt out of ad targeting from member companies.
When you opt out of receiving Interest Based Advertisements a cookie is placed on your computer that informs applicable advertisers that you do not wish to receive Interest Based Advertisements. The cookie is specific to the web browser you were using when you elected to opt out. If you access the Internet through a different browser, or clear your browser’s cookies, advertisers will not know that you do not wish to receive Interest Based Advertisements. In either case, you must repeat the opt out process to reset your preferences.
Opting out of receiving Interest Based Advertisements does not mean that SMP or the third party advertisers will no longer collect information; however, so long as the opt out cookie is on your browser, it does mean that the third party advertisers from whom you have opted out of receiving Interest Based Advertisements will not display advertisements to you which are tailored to your apparent interests using information collected through cookies and other tracking tools facilitated by our website or the applicable third party advertiser.
Refusing to Accept Cookies
Most web browsers allow you to modify your browser’s settings so that it does not accept cookies. Doing so may also allow you to opt out of receiving Interest Based Advertisements. However, some functionality of our site may be impaired and you may not be able to access some of the areas of our site, which require cookies for customization and personalization.
If you do not know how to modify your browser settings please consult your browser documentation. You may visit the SMP website with your cookies turned off. If you elect to modify your browser settings so that your browser does not accept cookies, you will need to repeat this process if you access the Internet through another browser.
Opting out of Interest Based Advertising or modifying your browser so that it refuses to accept cookies will not opt you out of all advertising, but rather only those advertisements that are tailored to your apparent interests using information collected through cookies and other tracking tools facilitated by our website or the applicable third party advertiser.
Third Party Applications
SMP may implement third party applications or on our website to promote our interactions with users of that third party’s services. These applications, such as our Twitter and Facebook feeds, are made available to us by the third party publisher of the application. These applications will be visible to you on the web pages where we have implemented them.
If you chose to interact with these applications, for example by clicking on a Facebook “like” button, you will typically allow the third party provider of that application to collect some information about you, including through cookies. In some cases, the third party provider of the application may recognize you through its application and its cookies even when you do not interact with the application.
WILL SMP SHARE MY INFORMATION WITH OTHER PARTIES?
We may disclose your personal information as permitted or required by law, in conjunction with a government inquiry, law enforcement activities or in litigation or dispute resolution. In addition, if a SMP service provider is located outside of Canada, your personal information may be collected, processed and stored in a country where the laws are different from those in Canada, and where local law enforcement or the local government (e.g. the U.S. government) may be able to obtain disclosure of your personal information under the local laws.
We may disclose to a third party, personal information as part of a prospective or actual business transaction involving SMP (including a sale or disposition, merger or amalgamation, financing, conveyance, lease or other business arrangement in respect of all or any portion of SMP or of any of the business or assets or shares of SMP or a division thereof) in order for you to receive the same products and services from the third party.
Finally, our website, www.buysmp.com, does contain links to sites outside of and not controlled by SMP such as those belonging to GM Canada, GM licensees, or independent product review sites. SMP is not responsible for these sites, their omissions or for the policies or content of the websites. We recommend that you read the privacy policies of these sites before making a decision to provide your personal information to the site operators.
HOW IS MY PERSONAL INFORMATION PROTECTED?
SMP retains your personal information for as long as necessary to fulfill the purposes for which it was collected, for legal or tax purposes, and to comply with applicable laws. Your consent to such purposes remains valid after termination of our relationship with you.
CAN I OPT-OUT OF SMP MARKETING PROMOTIONS AND INITIATIVES?
If you do not want to be contacted for product, service or marketing initiatives, or if you would like to be removed from any direct marketing initiatives, corporate surveys, telemarketing or direct mail or e-mail lists, or if you would otherwise like to limit our use or disclosure of your personal information, please contact us as indicated below.
Except as required or permitted by applicable law, we will respect your wishes relating to the use of your personal
information and we will ensure that your file reflects the limitations that you have requested. Unless they are obvious, we will advise you of the consequences of withdrawing your consent. For example, if you withdraw your consent, SMP may not be able to provide you or continue to provide you with the services or information about products or services or related promotions that may be of value to you.
HOW CAN I ACCESS AND CORRECT ERRORS IN MY INFORMATION?
You can access and correct errors in your personal information by contacting us as indicated below. While SMP uses reasonable efforts to ensure that the information we hold about you is accurate, complete and current, we often rely on you to inform us about changes to your contact or other relevant information (e.g., name, address, telephone number, change of vehicle ownership, etc.).
Note: If a correction involves your GM vehicle or service, you will be asked for your Vehicle Identification Number (VIN), name, address and additional contact information.
HOW DO I CONTACT SMP?
SMP is committed to continuous improvement and values your input. We welcome your comments and/or suggestions on improving our website and policies. If you have any comments or concerns regarding our privacy practices, wish to receive information regarding our policies and procedures with respect to service providers outside of Canada, or wish to limit the use or disclosure of your personal information that we may have, you may contact GM Canada at:
You may also contact us by clicking on the “CONTACT US” icon found on the SMP website. Should you have any questions or concerns regarding the collection, use or disclosure of your personal information, please do not hesitate to contact us.
If you have followed this process and we have been unable to resolve your concern, you may also contact The Office of the Privacy Commissioner of Canada at Place de Ville, 112 Kent Street, 3rd Floor, Ottawa, Ontario K1A 1H3, or call toll-free at 1-800-282-1376