Privacy Policy. Mercedes-Benz Canada Inc. Version 3.0

Transcription

1 Privacy Plicy Mercedes-Benz Canada Inc. Versin 3.0 Privacy Plicy Versin 3.0 Page 1 f 15 January 16, 2018

2 Cntents Intrductin 3 Definitins 3 Hw is MBC Accuntable? 4 What Persnal Infrmatin Des MBC Cllect? 4 Fr What Purpses Des MBC Use Persnal Infrmatin? 8 MBC Cllects Persnal Infrmatin with Cnsent 10 MBC Limits its Cllectin f Persnal Infrmatin 10 MBC Limits its Use, Disclsure, and Retentin f Persnal Infrmatin 11 MBC Uses Reasnable Safeguards t Prtect Persnal Infrmatin 12 MBC Is Open Abut its Privacy Practices 13 MBC Maintains Accurate Persnal Infrmatin and Permits the Crrectin and Access 13 Hw t Cntact MBC 14 Privacy Plicy Versin 3.0 Page 2 f 15 January 16, 2018

3 Intrductin At Mercedes-Benz Canada Inc. (MBC), we demnstrate ur cmmitment t prtecting the persnal infrmatin f ur custmers thrugh the MBC Privacy Plicy. This Plicy describes hw we prtect the privacy, cnfidentiality, accuracy, and security f custmer persnal infrmatin that we cllect, use, disclse, r retain at MBC, including at ur crprately wned dealerships. MBC is part f the Daimler AG Grup f cmpanies, ne f the wrld s leading autmtive manufacturers. MBC and ur affiliated businesses are required t cmply with the Daimler Cde f Cnduct fr Data Prtectin and Privacy 1 and t cmmunicate and enfrce this Privacy Plicy. The MBC Privacy Plicy cmplies with the Daimler Cde f Cnduct fr Data Prtectin and Privacy, the Persnal Infrmatin Prtectin and Electrnic Dcuments Act (PIPEDA), the Canadian Marketing Assciatins Cde f Ethics and Standards f Practice, and, if applicable, prvincial privacy laws. The MBC Privacy Plicy is rganized arund ten internatinally recgnized privacy principles, which are cdified int law in Schedule I f PIPEDA. We reserve the right t change this Plicy frm time t time and prvide ntice f any significant changes, and the prpsed effect, n the MBC website. In additin, we include a revisin date n each versin f ur Plicy. By prviding persnal infrmatin t us, r cntinuing t use ur prducts r services after that date, custmers cnsent t the cllectin, use and disclsure f the persnal infrmatin as set ut in the Plicy. Definitins The fllwing definitins apply in this Privacy Plicy: Affiliated Businesses: Our affiliated lines f businesses and prgrams that develp, enhance, market, and/r prvide MBC cnsumer prducts, services, and marketing. Affiliated businesses include Daimler AG, Mercedes-Benz Financial Services Canada Crpratin, independent Mercedes-Benz Canada dealerships, and all wrldwide subsidiaries f Daimler AG. Business Partners: Organizatins with which we have an alliance r arrangement t prvide ur custmers with prducts r services that may be f interest t them, but which we d nt ffer directly. Business partners als include rganizatins with which we partner in rder t cnduct market research s that we may better understand ur custmers interests and autmtive needs. Cllectin: Gathering, acquiring, r btaining custmer persnal infrmatin frm any surce. Cnsent: A custmer s vluntary agreement with what is being dne r prpsed. Cnsent may either be implied r express. Express cnsent is given in an explicit manner, either rally r in writing. Implied cnsent may be reasnably inferred by the actin r inactin f the individual (e.g. custmer presenting a driver s license s we can authrize a test drive). 1 Privacy Plicy Versin 3.0 Page 3 f 15 January 16, 2018

4 Custmer: An individual persn wh purchases, r expresses an interest in, an MBC prduct r service. This includes ptential custmers with whm we have established, r are in the prcess f establishing, a custmer prfile by cllecting persnal infrmatin. Disclsure: Making persnal infrmatin available t ther individuals r rganizatins utside f MBC, including t ur affiliated businesses. Persnal Infrmatin: Infrmatin that identifies, r which culd be used either alne r with ther infrmatin t identify a custmer, such as name, address, birth date, financial infrmatin, cmputer IP address, etc. In accrdance with legal requirements, if custmers identify themselves as emplyees f an rganizatin, their name, title, business address, r business telephne number is nt cnsidered persnal infrmatin. Cntractrs: Organizatins r individuals that perfrm services n ur behalf and fr ur purpses. Fr the purpse f this plicy, references t MBC include cntractrs. Use: Handling r prcessing f persnal infrmatin within MBC. Hw is MBC Accuntable? At MBC, we are respnsible fr all persnal infrmatin in ur custdy r cntrl, including persnal infrmatin that we share with cntractrs perating n ur behalf (e.g. infrmatin technlgy prviders). We require all f ur emplyees (permanent and cntract) wh handle persnal infrmatin t sign cnfidentiality agreements t ensure that they prtect persnal infrmatin in cmpliance with this Plicy. Our agreements with ur suppliers als cntain cnfidentiality prvisins. We have designated a Privacy Officer wh is ultimately respnsible fr ensuring ur cmpliance with this Privacy Plicy. Custmers and MBC emplyees can cntact the MBC Privacy Officer with questins, cmments, r cmplaints (see Hw t Cntact MBC sectin belw). T help ensure the effectiveness f ur Privacy Plicy, we: Adpt privacy prcedures and prcesses t prtect persnal infrmatin; Respnd t privacy cmplaints and inquiries in a timely manner; Cnduct regular privacy training fr all emplyees (permanent and cntract); Make infrmatin available t custmers t explain ur privacy plicies and prcedures (e.g. privacy ntices, statements, brchures); and Mnitr legislative and industry develpments in privacy and security n an n-ging basis t ensure we are meeting r exceeding ur privacy and security respnsibilities. What Persnal Infrmatin Des MBC Cllect? MBC cllects persnal infrmatin in a variety f ways: directly frm custmers when they prvide it, indirectly frm their devices and nline use, frm ther third parties, frm a custmer s vehicle and frm special service r features we prvide r custmers purchase. We describe these ways in mre detail belw. Privacy Plicy Versin 3.0 Page 4 f 15 January 16, 2018

5 Frm custmers: We may cllect persnal infrmatin when a custmer prvides their infrmatin t us directly, such as when they cntact us r when they enter their persnal infrmatin n ur websites. Our websites include this website ( ur Mercedes me website (mercedesme.ca) and ther sites wned, perated, r cntrlled by MBC and n which this Privacy Plicy is psted ( ur website(s) ). Fr example: We may cllect and use the persnal infrmatin that such custmers prvide t us via their accunt: fr instance, custmer name, address, cuntry f residence, passwrd and ther registratin infrmatin; the status f an rder; warranty and ther dcumentatin fr MBC prducts and general infrmatin abut such prducts (including, fr example, vehicle identificatin number r ther prduct serial number, service plan infrmatin, cnnectivity package, subscriptin r service infrmatin), insurance frms, driver s licenses, financing agreements, and similar infrmatin. Custmers wh wish t arrange vehicle financing thrugh Mercedes-Benz Financial Services Canada Crpratin may be asked t prvide their address, driver s license number, year f birth, prperty wnership status, mrtgage/rent payment, balance, scial insurance number (ptinal), emplyment infrmatin/histry, incme, banking infrmatin and infrmatin abut legal actins. MBC sends this t Mercedes-Benz Financial Services Canada Crpratin where credit may be apprved r declined. Payment infrmatin, including payment card r accunt infrmatin, if a custmer makes a purchase s that we can prcess the transactin. Infrmatin abut the vehicle with which the custmer is assciated, such as purchase infrmatin, service histry, and type f vehicle, which we use t keep warranty and service recrds. Name and cntact infrmatin f custmers wh participate in an nline chat (where available) with ne f ur MBC representatives s that we can lcate ur discussin and fllw-up with if necessary. We may cllect infrmatin abut custmers ffline, such as when a custmer visits MBC r an Affiliated Business, attends ne f ur events, signs up fr a test drive, places an rder ver the phne, r cntacts ur custmer services r sales department. Frm custmer devices: We cllect persnal infrmatin frm ur custmer s devices, including: Thrugh ur digital services, including ur website, ur sftware applicatins, scial media pages, and in r text messages. Autmatically when a custmer uses a brwser r their device. This infrmatin may include a custmer s Media Access Cntrl (MAC) address, type f cmputer r device, screen reslutin, perating system name and versin, device manufacturer and mdel, language, Internet brwser type and versin, and the name and versin f the services (e.g. the Mercedes me App) the custmer is using. Privacy Plicy Versin 3.0 Page 5 f 15 January 16, 2018

6 Bth MBC and its third party service prviders, autmatically when a custmer visits ur website, via ckies, web beacns and ther digital markers: Ckies MBC r ur advertisers r ther third parties may send a ckie t a persn s cmputer. A ckie is a small piece f data that is sent t an individual s Internet brwser frm a web server and stred n a persn s cmputer hard drive and that can be re-sent t the serving website n subsequent visits. A ckie, by itself, cannt read ther data frm the cmputer s hard disk r read ther ckie files already n the cmputer. MBC, its advertisers and ther third parties may use ckies t identify and keep track f, amng ther things, thse areas f the website and third party websites that individuals have visited in the past in rder t enhance their next visit t the website. MBC als gathers statistical infrmatin abut the usage f the digital services in rder t cntinually imprve their design and functinality, understand hw the digital services are used, and assist us with reslving questins regarding the digital services. Ckies als allw MBC, in the case f ur third party advertisers, t prvide individuals with nline advertising and t custmize the srt f advertisements advertisers prvide. Ckies may als be used in nline advertisements t see hw individuals interact with MBC advertisements. Individuals may be able t chse whether r nt t accept ckies by changing the settings f their Internet brwser, but sme functinality f the website may be impaired r nt functin as intended. Web Beacns Sme f MBC s web pages and electrnic cmmunicatins may cntain web beacns (smetimes referred t as pixel tags ). Web beacns cllect nly limited infrmatin, including: a ckie number; time and date f a page view; and a descriptin f the page n which the web beacn resides. We may als carry web beacns placed by third party advertisers. These web beacns d nt carry any persnal infrmatin and are nly used t track usage f the website and activities assciated with the website. Unique Identifier We may assign custmers a unique internal identifier t help keep track f their future visits. We use this infrmatin t gather aggregate demgraphic infrmatin abut custmers, and we use it t persnalize the infrmatin custmers see n the website and sme f the electrnic cmmunicatins custmers receive frm us (if they have they prvided their cnsent t receive such cmmunicatins). We keep this infrmatin fr ur internal use, and this infrmatin is nt shared with thers. Frm ther third parties: We may als cllect persnal infrmatin frm ther surces, such as retailers, cnsumer reprting agencies, gvernment agencies, ur Affiliated Businesses, insurance prviders and thers. Fr example: Privacy Plicy Versin 3.0 Page 6 f 15 January 16, 2018

7 We cllect credit infrmatin frm cnsumer reprting agencies if a custmer seeks t finance r lease a vehicle frm MBC. We cllect infrmatin abut custmers frm retailers t administer a purchase f a Mercedes-Benz vehicle and share repair r maintenance infrmatin abut a custmer s vehicle when that custmer seeks service frm ther prviders. We may btain infrmatin abut custmers frm gvernment agencies in rder t ensure that custmers have nt vilated their agreement regarding exprting a vehicle r in rder fr us t lcate and repssess a leased r financed vehicle. We als may receive infrmatin abut custmers frm ther surces, such as public databases, jint marketing partners, certified installers, third-party vehicle repair r service centers, and scial media platfrms. Frm the vehicle: Telematics refers t the use f wireless devices and technlgies t transmit data in real time back t an rganizatin. Many Mercedes-Benz vehicles are equipped with telematics functinality. MBC may cllect certain telematics data regarding the perfrmance, usage, peratin, and cnditin f a custmer s vehicle t imprve ur vehicles and services. The types f data cllected will vary amng vehicle mdels, as well as the types f services available r selected by the custmer. Fr example: The telematics data cllected by MBC may include: vehicle identificatin number; speed infrmatin; mileage; fuel level and average fuel cnsumptin; tire pressure; battery charge infrmatin; electrical system functins; sftware versin infrmatin; inftainment system data; safety-related data and camera images (including, e.g., infrmatin regarding the vehicle s SRS systems, braking and acceleratin, security, and accidents); shrt vide r audi clips f accidents; infrmatin regarding the use and peratin f varius features; gepsitin and lcatin infrmatin; and ther data t assist in identifying issues and analyzing the perfrmance f the vehicle. We may cllect such infrmatin either in persn (such as during a service appintment) r via remte access. In vehicles in which the emergency call system is activated, MB Canada may cllect: the vehicle's gepsitin data and the gepsitin data f the rute (i.e. several hundred metres immediately befre the befre the triggering incident ccurred); the directin f travel; vehicle identificatin number; if the vehicle is a car, the type f vehicle drive (e. g. petrl engine, hybrid vehicle); the estimated severity f the accident; the estimated number f peple in the vehicle; whether r nt the vehicle supprts accident management; whether Mercedes me cnnect is available r nt; whether the emergency call was triggered autmatically r manually; the time f the triggering incident; and the language setting in the multimedia system. MBC may be able t remtely cnnect t a custmer s vehicle t diagnse and reslve issues with the vehicle. This als enables us t view the current lcatin f the vehicle and may als prvide us with infrmatin regarding persnal settings in the vehicle, such as cntact lists, brwsing histry, navigatin histry, and radi listening histry. This infrmatin is nly visible t the authrized users f this custmer assistance platfrm. Privacy Plicy Versin 3.0 Page 7 f 15 January 16, 2018

8 We may cllect and stre ther vehicle data such as: accident infrmatin (e.g., air bag deplyment, sensr data); remte services/vehicle setup infrmatin (e.g., remte lck/unlck, climate cntrl, vehicle status, etc.); vehicle cnnectivity infrmatin; data abut issues that culd materially impair peratin f the vehicle r safety-critical issues; and data abut each sftware and firmware update. We may cllect such infrmatin either during a service appintment r via remte access. In rder t facilitate the servicing f the vehicle, we may cllect and prcess data abut the service histry f each vehicle, including custmer name, vehicle identificatin number, repair histry, utstanding recalls (if any), any bills due, any custmer cmplaints, and ther infrmatin related t its service histry. Frm special features: Custmers may subscribe t r purchase certain features in their vehicle (fr instance, live traffic feature, tracking services, navigatin services, rute planning r ther features which make use f lcatin data f the vehicle, and we may share this data with partners that cntribute similar data t help us prvide the service. MBC may cllect similar data in cnnectin with ther features and may share it with business partners where necessary t prvide the feature t the custmer, but we will nly cllect and share the data in a way that des nt persnally identify the custmer. While we nly cllect and share this data if these features are enabled in the vehicle, the vehicle may send this data t MBC and its partners even if the feature is nt in active use. Custmers may cntact us (see Hw t Cntact MBC sectin belw) t enquire abut stpping the transmissin f MBC telematics data ther vehicle data. T stp transmissin, disablement f the vehicle s telecmmunicatins mdule will be required. This can nly be perfrmed by a Mercedes-Benz technician. Once the unit is disabled, we will nt be able t ntify the custmer f vehicle issues in real time, which may reduce vehicle functinality, result in serius damage t, r inperability f, the vehicle. In additin, if custmers d nt prvide telematics data, this may result in many features f the vehicle being disabled, including remte services, interactivity with the Mercedes me cnnect mbile app, and any service r feature that utilizes wireless internet cmmunicatin Fr What Purpses Des MBC Use Persnal Infrmatin? At MBC, we identify t ur custmers the purpses fr which we cllect their persnal infrmatin at r befre the time f cllectin. We make this infrmatin available t custmers thrugh this Privacy Plicy, ur website, privacy ntices, and ther infrmatinal materials available at ur dealerships. We d nt cllect, use, r disclse persnal infrmatin fr a new purpse that was nt previusly identified withut, first, explaining the new purpse t the custmer and, secnd, btaining cnsent. We cllect and use persnal infrmatin fr many purpses, including t: Privacy Plicy Versin 3.0 Page 8 f 15 January 16, 2018

9 Prvide ur custmers with MBC prducts r services and related activities, such as administer vehicle warranty prgrams; custmizatin, financing, leasing, recalls, test drives, and custmer lyalty prgrams; Initiate, maintain, and imprve ur relatinship with ur custmers by prviding them with persnalizatin f their experience, including t: remember custmer interests and preferences; custmize the prducts and services we share with custmers; facilitate custmer interactins with ur emplyees; track and categrize custmer activity and interests n ur website and mbile applicatin and t enrich the custmer experience in ur dealerships, n ur website, and thrugh ur mbile applicatin; Cmmunicate with ur custmers, such as: respnding t a custmer when they place an rder; call us; make a request r inquiry; enter a cntest r sweepstakes; cmplete a survey; r share a cmment r cncern. As well, we use this infrmatin t respnd t and investigate custmer inquiries, send custmers newsletters, vehicle infrmatin, brchures, alerts r ther materials; t request and prvide feedback; and t facilitate scial sharing and cmmunicatin; Facilitate a transactin and prvide prducts and services, such as: t cmplete and fulfill a purchase r rder, t prcess a payment, prcess, maintain r service an accunt r membership, have an rder delivered, cmmunicate regarding a purchase; service an accunt and prvide related custmer service; Imprve ur prducts and services thrugh quality assurance and imprvement activities, including t: develp and prmte new prducts and services; t imprve r mdify ur existing prducts and services; and t analyze and imprve the safety and security f ur prducts and services. Mnitr vehicle perfrmance and prvide services related t the vehicle, such as: cntact the custmer with service recmmendatins and t deliver ver-the-air updates t the vehicle; t deliver any services requested by the custmer; and cmply with legal and cntractual requirements; Perfrm analytics, such as t: understand hw custmers use ur website, mbile applicatins, prducts and services; generate insights and understand hw custmers interact with us; and imprve ur website, mbile applicatins, prducts and services; Operate and imprve upn ur business and lawful business activities; t maintain ur prgrams, accunts, and recrds; fr research; t determine custmer satisfactin with ur prducts and services; t detect and prevent fraud r misuse f ur services; Lcating and repssessing a leased r financed vehicle exprted frm Canada in vilatin f agreements r t mnitr cmpliance with such agreements; and Defend r prtect us, ur custmers, r third parties, frm harm r in legal prceedings; prtect ur rights; prtect ur security and the security f ur custmers, emplyees, and prperty; respnd t curt rders, lawsuits, subpenas, and gvernment requests; address legal and regulatry cmpliance; and ntify custmer f prduct recalls r safety issues. Privacy Plicy Versin 3.0 Page 9 f 15 January 16, 2018

10 MBC Cllects Persnal Infrmatin with Cnsent We btain the cnsent f custmers fr the cllectin, use, r disclsure f their persnal infrmatin, except where it is inapprpriate t d s. Fr sensitive uses and disclsures f persnal infrmatin, such as disclsing financial infrmatin t Mercedes-Benz Financial Services Canada Crpratin fr the purpse f prcessing a request t lease r finance a vehicle, we btain the express cnsent f custmers. In additin, we btain the implied cnsent f ur custmers by prviding ntice f ur privacy practices thrugh the MBC Privacy Statement, lcated thrughut MBC dealerships and n ur website. At MBC, we d nt, as a cnditin f sale r service, require a custmer t cnsent t the cllectin, use, r disclsure f persnal infrmatin beynd that required t fulfill the specified purpses. Custmers may chse t withdraw their cnsent fr certain uses and disclsures f their infrmatin by us at MBC, subject t legal r cntractual restrictins and reasnable ntice. Custmers can pt ut f these uses and disclsures by cntacting ur MBC Privacy Officer (see Hw t Cntact MBC sectin belw). Custmers can withdraw their cnsent t ur use and disclsure f their persnal infrmatin fr the fllwing purpses: Prviding ur custmers with infrmatin n special ffers, events, and prmtins ffered by us at MBC r ur business partners; Cntacting ur custmers directly r thrugh a business partner, such as JD Pwer r Maritz, in rder t survey ur custmers level f satisfactin with ur prducts and services and t enable us t better understand ur custmers interests and needs; r Enrlling ur custmers t receive a 6 mnth free trial f SIRIUS Satellite Radi. 2 Once we receive a custmer s pt-ut request, we prcess it within 10 days. If custmers chse t withdraw their cnsent fr any f the abve-mentined reasns, the MBC Privacy Officer will identify the implicatins f such refusals when the request is received and, if applicable, infrm custmers f any restrictins n their withdrawal f their cnsent. Please nte that MBC is unable t prcess pt-ut requests n behalf f ur affiliated businesses and business partners. Custmers must cntact these businesses directly t pt ut. MBC Limits its Cllectin f Persnal Infrmatin At MBC, we limit the cllectin f persnal infrmatin t that which is necessary fr the purpses identified t ur custmers, and cllect persnal infrmatin thrugh fair and lawful means. Fr example, we limit the infrmatin we cllect frm drivers licenses fr the purpse f test driving a vehicle by nly recrding the infrmatin required t verify the driver s license and 2 In rder t activate custmers SIRIUS Satellite Radi free trial, MBC prvides SIRIUS with a custmer s name, address, phne number, vehicle identificatin number, and SIRIUS Satellite Radi serial number. If custmers d nt want their infrmatin t be prvided t SIRIUS, they must pt ut f the free trial within 48 hurs f the time f vehicle delivery. Privacy Plicy Versin 3.0 Page 10 f 15 January 16, 2018

11 t identify the driver in case f vehicle theft, accident, ticket, r ther liability. We als limit the cllectin f custmer financial and cntact infrmatin by nly cllecting infrmatin deemed necessary t prcess a transactin and fr business develpment purpses. MBC Limits its Use, Disclsure, and Retentin f Persnal Infrmatin We d nt use r disclse custmer persnal infrmatin fr purpses that are nt identified at the time f cllectin, except with the cnsent f the custmer r as therwise required r permitted by law. Custmers may request a representative list f the rganizatins t which we disclse their persnal infrmatin by cntacting the MBC Privacy Officer (see Hw t Cntact MBC sectin belw). We may disclse persnal infrmatin t third parties, including the fllwing: T Mercedes-Benz Financial Services Canada Crpratin, gvernment institutins (e.g. departments f mtr vehicles r ther relevant agencies), and insurance prviders in rder t prcess the purchase, lease, finance, r maintenance f a vehicle T scial media accunt prviders, if a custmer cnnects their scial media accunt with MBC r vehicle functinality; Third party cntest prviders, prmtins r lyalty prgrams, if a custmer elects t participate; T business partners, such as: Mercedes-Benz dealerships nt wned by MBC; SIRIUS Satellite Radi and Radside Assistance, s that they can prvide ur custmers with prducts and services n a trial r fee-fr-service basis frm these businesses; Maritz and JD Pwer, s that these businesses may request infrmatin frm custmers cncerning the quality f ur services and prducts as well as cnduct market research s that we can better understand ur custmers and their needs. 3 On rare ccasins, we may disclse custmer persnal infrmatin withut custmer knwledge r cnsent where we are required r permitted by law t d s. When we are required r permitted by law t prvide infrmatin, we take reasnable steps t verify the lawful authrity (where applicable) fr the cllectin and we disclse nly the infrmatin that is legally required r therwise permitted t be disclsed. We may share persnal infrmatin with ur service prviders and business partners when necessary t perfrm services n ur r n the custmer s behalf, such as: 3 Disclsures t business partners such as Maritz and JD Pwer nly ccur with the persnal infrmatin f existing custmers nt ptential custmers (i.e. individuals, businesses, r rganizatins that purchase an MBC prduct r service nt thse wh nly express an interest in purchasing an MBC prduct r service). Privacy Plicy Versin 3.0 Page 11 f 15 January 16, 2018

12 With ur Business Affiliates fr the purpses described herein. With third parties that prvide services t MBC, such as web hsting, data analytics, payment prcessing, IT services, vice cmmand prcessing, custmer service and similar prcessing activities. With ur business partners t help develp and market prgrams, prducts r services and present targeted cntent including targeted advertising. With ther third party businesses, if they are invlved in the transactin a custmer is engaged in (e.g., finance cmpanies, leasing cmpanies, registratin services, title registratin). MBC retains custmer persnal infrmatin nly as lng as it is required fr ur business relatinship r as required by law. We fllw established prcedures cncerning the retentin f persnal infrmatin. Persnal infrmatin that is n lnger required t fulfill the specified purpses is securely destryed (e.g. shredded) r erased (e.g. sanitized fr electrnic media) r annymized. In the unlikely event that MBC, any f its Affiliated Businesses, brands r substantially all f any f their assets are acquired by an unrelated third party, custmer persnal infrmatin may be ne f the transferred assets. By prviding persnal infrmatin t us, custmers agree that we may disclse their persnal infrmatin, n a cnfidential basis, t any prspective transferee and its prfessinal advisrs fr the purpses f their due diligence investigatins, the cmpletin f any such transactin and the cntinued peratin f the acquired business. MBC Uses Reasnable Safeguards t Prtect Persnal Infrmatin We prtect persnal infrmatin against lss, theft, and unauthrized access, disclsure, cpying, use, r mdificatin with security safeguards apprpriate t the sensitivity f the persnal infrmatin. We prtect persnal infrmatin regardless f the frmat in which it is held. At MBC, we cmply with industry practices and emply reasnable security prcedures t prtect persnal infrmatin in ur custdy and cntrl. These include, but are nt limited t, the fllwing safeguards: Administrative Safeguards: We emply reasnable administrative safeguards, such as this Privacy Plicy, cnfidentiality agreements, and cntracts, t ensure that all MBC emplyees (permanent and cntract) access persnal infrmatin fr authrized purpses nly. We train ur emplyees (permanent and cntract) t understand and fllw the practices utlined in this Privacy Plicy, and regularly remind them f their privacy respnsibilities. Technical Safeguards: We emply reasnable technical safeguards, such as passwrds, encryptin, clear screen plicy, the use f clsed netwrks, and rle-based access cntrls, fr infrmatin systems frm which persnal infrmatin may be accessed. Physical Safeguards: We emply reasnable physical safeguards t prtect persnal infrmatin, such as by lcking filing cabinets and by restricting physical access t ffices and data centres. Privacy Plicy Versin 3.0 Page 12 f 15 January 16, 2018

13 We als prtect the persnal infrmatin we destry and dispse f in rder t prevent unauthrized parties frm gaining access t the infrmatin during this prcess. This includes shredding paper dcuments and erasing electrnic data. Unfrtunately, n data transmissin r strage system is guaranteed t be 100% secure. If a custmer has any reasn t believe that their accunt, transactin r infrmatin is n lnger secure, they shuld cntact us immediately (see the Hw t Cntact MBC sectin belw.) Custmers wh sell r transfer their vehicle t anther persn may need t take additinal steps t safeguard their persnal infrmatin frm being disclsed t the new wner f the vehicle. Please ntify us s that we can assist with any necessary additinal steps. Please nt that persnal infrmatin may be stred and prcessed in any cuntry where MBC r its Affiliated Businesses are lcated, r engages service prviders. Thse cuntries may nt have the same data prtectin laws as Canada. When we transfer infrmatin frm r abut custmers r custmer use f ur prducts r the services t ther cuntries, we will prtect it as described in this Privacy Plicy. By using ur prducts, the services, r therwise prviding infrmatin t us, custmers cnsent t the transfer f their persnal infrmatin t cuntries utside f Canada. MBC Is Open Abut its Privacy Practices At MBC, we make available t ur custmers specific infrmatin abut ur plicies and practices that relate t the management f custmer persnal infrmatin. We make this infrmatin available t ur custmers: In this Privacy Plicy and ur privacy statement fund n the MBC website; Thrugh ur privacy ntices that we pst and make available at MBC dealerships; and Via ur Privacy Officer (see Hw t Cntact MBC sectin belw) The management f custmer persnal infrmatin by ur Affiliated Businesses and business partners is gverned by the privacy plicies f thse businesses and is nt the respnsibility f MBC. Please cntact these businesses directly fr infrmatin abut their respective data management practices. MBC Maintains Accurate Persnal Infrmatin and Permits the Crrectin and Access At MBC, we make reasnable effrts t ensure that persnal infrmatin we use r disclse is as accurate, cmplete, and up-t-date as is necessary fr the specified purpse. This depends n the use f the infrmatin and takes int accunt the interests f the custmer. Fr example, accuracy f infrmatin is particularly imprtant if Mercedes-Benz Financial Services Canada Crpratin is using this infrmatin t make a judgment r evaluatin abut a custmer, such as fr credit checks. Sme custmer infrmatin can be mdified r crrected by the custmer if they lg in t their accunt t make such changes. Custmers may als cntact us shuld their infrmatin (e.g. address, vehicle wnership infrmatin) change (see Hw t Cntact MBC sectin belw). Privacy Plicy Versin 3.0 Page 13 f 15 January 16, 2018

14 Upn written request, we will infrm ur custmers f the existence, uses, and disclsures f their persnal infrmatin and give them access t that infrmatin, except where we are restricted frm ding s by law. Custmers shuld make clear in their request what infrmatin they wuld like t have changed, whether they wuld like t have their persnal infrmatin suppressed frm ur database, r therwise let us knw what limitatins they wuld like t put n ur use f the infrmatin they have prvided t us. Custmers can request access t their persnal infrmatin in ur custdy r cntrl by cntacting ur Privacy Officer (see Hw t Cntact MBC sectin belw). If MBC is unable t prvide access t all f the persnal infrmatin that we hld abut a custmer, we prvide the reasns fr denying access t the custmer. A custmer will be required t prvide sufficient infrmatin s that we can cnfirm the custmer s identity and prcess the custmer s request. We nly use the infrmatin prvided t accurately lcate the custmer s persnal infrmatin. We will respnd t all requests fr access t infrmatin within 30 business days frm the receipt f request and at minimal r n cst t the individual. In the case where there is a cst assciated with prcessing the request, we ntify the custmer in advance. The custmer may then chse t withdraw his/her request. If a custmer finds that the infrmatin prvided t him/her is inaccurate r incmplete, the custmer may cntact ur Privacy Officer (see Hw t Cntact MBC sectin belw) and we will amend this infrmatin, as apprpriate. When apprpriate, we will als transmit the amended infrmatin t the rganizatins t which we riginally shared the infrmatin s that the infrmatin is crrect and cmplete within the rganizatins recrds. If we determine that it is inapprpriate t amend a custmer s infrmatin, we will nte this within ur recrds. Please nte that we may need t retain certain infrmatin fr recrdkeeping r legal cmpliance purpses and/r t cmplete any transactins that a custmer began prir t requesting such change r suppressin (fr instance, if a custmer makes a purchase r enters a prmtin, we may be unable t change r suppress the infrmatin prvided until after the cmpletin f such purchase r prmtin). There may als be residual infrmatin that will remain within ur databases and ther recrds, which will nt be remved. Hw t Cntact MBC Individuals may direct inquiries, cmments r cmplaints by submitting them in writing t the MBC Privacy Officer at: By mail: By Privacy Officer 98 Vanderhf Ave Trnt, ON M4G 4C9 Privacy Plicy Versin 3.0 Page 14 f 15 January 16, 2018

15 Custmer may als make inquires be calling us at The MBC Privacy Officer reviews all cmplaints within 5 business days. If a cmplaint is fund t be justified, ur Privacy Officer will cnduct an investigatin and take apprpriate measures t remediate the issue, including, if necessary, amending ur plicies and prcedures, safeguards, and infrmatin management practices. The MBC Privacy Officer will infrm the cmplainant f the results f the investigatin within 30 business days frm the receipt f the cmplaint. When investigatins require mre time in rder t thrughly review the issue, ur Privacy Officer will prvide the cmplainant with a timeline fr cmpletin f the investigatin. In the event that we are nt able t address a cmplaint t the satisfactin f the cmplainant, he/she may cntact the Office f the Privacy Cmmissiner f Canada by phne ( ) r by filling ut a cmplaint frm available at and submitting the cmpleted frm by mail t: Office f the Privacy Cmmissiner f Canada 12 Kent Street Place de Ville, Twer B 3rd Flr Ottawa, ON K1A 1H3 Privacy Plicy Versin 3.0 Page 15 f 15 January 16, 2018