Privacy Policy

Protecting the privacy of personal information is a core concern for Gestion Lac 2000 inc. We are committed to respecting this Privacy Policy (hereinafter the "Policy") to guarantee a high level of protection for information collected from users of our services. We also commit to implementing consistent practices related to the protection of personal information and to clearly communicating these practices.

This Policy applies to users (hereinafter "you") of the services offered by Gestion Lac 2000 inc. (hereinafter "we") through our website, namely ADWS Auto Dealer Web Services, and at our dealership location.

This Policy describes the various situations in which Gestion Lac 2000 inc. collects, uses, discloses, and retains the personal information of users.

1Consent

1.1Personal Information

By browsing our website, you acknowledge having read, understood, and agreed to be bound by all the clauses contained in this Privacy Policy, as published on our website. You also affirm that you are of legal age under Canadian and Quebec law or that you are legally authorized to browse this site.

By voluntarily providing personal information about yourself on our website, you implicitly consent to our collecting, disclosing, using, and retaining such data for the purposes for which you initially consented to provide it, for the duration necessary to fulfill those purposes. (Art. 8.3 and 14 LP) Only the personal information necessary is collected, disclosed, used, and retained unless the law authorizes otherwise.

Before using personal information for purposes other than those for which it was initially provided, we commit to obtaining your consent. (art. 12 LP)

1.2Sensitive Personal Information

For the collection and use of sensitive personal information, each user must provide express consent, without which we will not be authorized to use such information. A personal information is considered sensitive "when, by its nature or the context of its use or disclosure, it gives rise to a high degree of reasonable expectation of privacy."

You may completely refuse to provide us with one or more sensitive personal information requested, in which case we may not be able to provide you with certain services that require the information in question.

1.3Withdrawing Consent

At any time, to withdraw your consent to any aspect of the management of your personal information by Gestion Lac 2000 inc., you simply need to contact the Privacy Officer by email. Please note that it is sometimes impossible to withdraw your consent if we are bound by legal or contractual requirements.

2Collection of Personal Information

2.1Forms

When you browse our website without providing any personal information, we do not collect any information that would allow us to identify you. However, to access certain services, a user must voluntarily provide the personal information necessary to obtain the requested service by completing a form.

The following information may be requested:

• Name
• Email address
• Identification numbers
• Phone number
• Physical address
• Date of birth
• Social insurance number
• Payment information (credit card or other payment method)
• Vehicle(s) of interest
• Estimated budget for vehicle purchase in dollars per month
• Whether they own a vehicle
• Estimated credit rating
• Interest in a zero-dollar down payment option
• Type of residence
• Mortgage or monthly rent amount
• Occupation
• Monthly income before taxes/deductions

The user may choose not to provide the requested personal information. However, they may not be able to access the requested services.

2.2Connection Logs

Each time you use our services, our servers automatically record the connection information your browser sends when connecting to our website. These server connection logs may contain non-personal information, such as:

• Your Internet search
• Your IP address
• The type and language of your browser
• The date and time of your connection
• The pages you visited
• One or more cookies to identify your browser.

If you voluntarily provide personal information when connecting to our site, it will be associated with the non-personal information collected in the connection logs. All of this information may then be shared with the dealership.

2.3Cookies

To be able to offer you certain services, we may also collect information through cookies. Cookies are small documents containing information exchanged between a browser and an internet server when a user visits a website.

Some cookies allow us to collect non-personal information that cannot be used to identify, locate, or profile users. These cookies allow, among other things, all users as a whole to navigate the website efficiently, to analyze and compile data on features used, to improve the performance of our website, and to measure user engagement with specific content.

We also use cookies that can collect, identify, or locate a user and/or perform profiling. These cookies will be disabled by default. Each user must enable these cookies when required upon entering our website.

2.3.1Information Collected via Cookies

• Basic Information: IP address, browser type, operating system, screen resolution, and approximate location.
• Session Identifier: maintains the state of the user's session.
• User Preferences: preferred language, site theme, or layout settings.
• Browsing History: pages visited, clicks made, and actions taken on the site.
• Authentication Information: allows the user to remain logged in.
• Advertising Preferences: types of preferred ads or products viewed.
• Social Media Data: social interactions, share buttons, and comments.
• Conversion Data: newsletter sign-up or product purchase to measure marketing effectiveness.
• Tracking Data: websites visited and browsing activities to deliver targeted ads.

2.3.2Types of Cookies Used

Cookies are either temporary or permanent. Temporary cookies are stored on your device only while you browse our website and are automatically deleted when you close your browser. Permanent cookies are not deleted when you close your browser and allow us to remember your preferences.

2.3.3Modifying Your Cookie Preferences

Only necessary cookies are enabled by default. Each user may then authorize or refuse other cookies. To change your consent regarding the use of cookies, please click the following link: Cookie Preferences or click the Cookie Preferences tab at the bottom of our website.

You may also change your cookie preferences through your browser or electronic device settings.

2.4User Communications with Us

When you send an email or any other communication to Gestion Lac 2000 inc., we may retain them to process your requests, answer your questions, and improve our services.

2.5Other Collection of Information

3Use and Processing of Personal Information

We only use personal information for the purposes for which a user has consented to it being collected. We do not rent, sell, or share any personal information about our website users.

We may need personal information in the following situations, for example:

• Establishing a file during the acquisition of a vehicle.
• Establishing, maintaining, and improving our relationship with you and offering you promotions or advertising programs.
• Contacting you to provide information about your purchase, lease, warranty, or maintenance program.
• Complying with our legal requirements.
• Honoring our contractual agreements regarding market orders or services.
• Conducting analyses to improve our products and services.

4Disclosure of Personal Information

We reserve the right to share your personal information with certain affiliated companies, vendors, agents, or other trusted companies or individuals who process it on our behalf in order to offer you personalized products and services, including financing.

4.1Disclosure in a Commercial Transaction

Furthermore, Gestion Lac 2000 inc. may share information you have voluntarily provided in connection with a commercial transaction, which includes operations such as mergers, acquisitions, or other modifications to the legal structure of the company. In the event of such a transaction, you will be notified before the transfer of your personal information and will be informed of the new privacy policy applicable to them. (Art. 18.4 LP)

4.2Disclosure to a Third Party

We may also share with third parties certain non-personal information in aggregate form. We may also transmit personal information collected through one of our forms directly to a CRM or a manufacturer's digital program manager.

We may also provide personal information in response to valid legal proceedings such as subpoenas, search warrants, and court orders, or to establish or exercise our rights or defend against legal claims.

We may also disclose personal information to financial institutions such as Fédérations des caisses, BMO, Banque Nationale, TD Trust, Scotiabank, Axis, Lendcare, RBC, IA Financial Group, and Iceberg Finance. (art. 18 et ss LP)

Gestion Lac 2000 inc. may also disclose personal information to its external suppliers, including Dealertrack, Gem-Car, Carquest Auto, Napa Auto Parts, and our partners: Mobials/Autoverify, Quickdealer, Cargurus, Industrielle Alliance, Cars Commerce, Groupe Acceo, Carfax, Equifax, Assurance Avantage Plus, Vend ton char, Location Accès Crédit, Autocop.ai, ADWS website, AMVOQ.

5Retention and Destruction of Personal Information

We retain personal information for the period during which we need it to provide the service requested by the user. If consent has been given for multiple purposes, we will retain the information until the purpose requiring the longest period has been fulfilled.

We also retain this information for any period required to comply with our legal obligations.

5.1Destruction or Anonymization

Once personal information has been used for the purposes for which the user gave consent, we will proceed with anonymization or destruction of the information while respecting the retention periods required by law. (23 LP)

6Security and Confidentiality of Personal Information

We take all necessary security measures to prevent any unauthorized access, modification, disclosure, or destruction of data. These measures include conducting internal audits on the collection, storage, and processing of information, as well as physical and software security measures. (art. 10 LP)

Personal information is encrypted at rest and always encrypted during backups. When you provide credit card information, it is encrypted.

We use TLS decryption and a secure SSH protocol when a user fills out an online form. To store data securely, we use MySQL databases located exclusively in Quebec with restricted access.

Access to personal information is strictly reserved for employees, agents, subcontractors, and representatives acting on behalf of Gestion Lac 2000 who need it for their work. These individuals are bound by confidentiality obligations and may be subject to sanctions up to and including dismissal and legal proceedings in case of breach. (art. 20 LP)

7User Rights Regarding Disclosed Personal Information

A user may at any time submit a request for access to or rectification of the file containing the personal information we hold about them if information is inaccurate, incomplete, or ambiguous. This request must be made in writing and must include proof confirming the identity of the user or their representative. (art. 30 LP)

Any user may request that the computerized personal information we hold about them be provided in an accessible and readable technological format. (art. 27 LP)

A user may also request that we delete information we no longer consider necessary to accomplish the purposes for which it was provided.

If we have reason to believe that a privacy incident involving users' personal information has occurred, we commit to taking reasonable steps to limit the risk of harm and to notifying the Commission d'accès à l'information and any affected users. (art. 3.5 LP) We also commit to maintaining a privacy incident register. (art. 3.8 LP)

8Links to Other Sites

When a user clicks on a link that leads to a website we do not own, it is their responsibility to review the privacy policy and cookie policy applicable to that site. This Policy applies only to our website and we are not responsible for the content of third-party websites.

9Amendments to the Policy

Please note that this Policy may be modified at any time. No change, even minor, that diminishes your rights under this Policy may take place without your express consent.

Regardless of the above, any changes made to this Policy will be published on this page. The date of the Policy update will be indicated at the top of the page. (art. 8.2 LP)

10Contact Information for the Privacy Officer

The Administrative Technician has been designated as the Privacy Officer at Gestion Lac. For any questions or comments, please contact the Privacy Officer using one of the following options: (art. 3.1 LP)