Privacy Policy

EFFECTIVE: October 27, 2020

Core Dealer Services, Inc. (“CDS” or “we”, “us” or “our”) respects your privacy. This Privacy Policy describes how we collect, use, share and safeguard your Personal Information.

Scope

“Personal Information” as used in this Privacy Policy means information about an identifiable individual. This Privacy Policy does not apply to Personal Information that we collect in our capacity as an employer; business contact information (including the name, title, business address and telephone number of an employee of an organization) that we collect in the course of our business dealings; or certain publicly available information.

Summary

Collection: We may collect your name and contact information, cookies and web tracking data from your visit to our website or use of our software (including the general geographic location associated with your IP address known as IP geolocation), payment information, business data, your business performance, feedback, reviews and testimonials and your social media content.

Use: We may use your Personal Information to deliver, maintain and improve our website, our software and services and your account, to analyze your business operations and evaluate its performance and to communicate with you.

Sharing: We may share your Personal Information with our employees and affiliates and third party service providers who act on our behalf to process your Personal Information, send communications or conduct marketing.

Consent: We may ask for your consent directly or imply your consent through your conduct.

Choices: You have choices regarding receiving electronic marketing messages from us and blocking cookies.

Cookies & Tracking Technologies: We use cookies and other tracking technologies to track your activity on our website and our software and to provide you with a more personal experience. You may configure your browser to block cookies.

Safeguards: We protect Personal Information using reasonable technological, administrative and physical security measures that are appropriate to the sensitivity of the Personal Information.

International Transfers: We transfer your Personal Information outside of Canada including to the U.S.A. for storing or processing by our third party service providers. Your Personal Information may be accessible to law enforcement agencies, government agencies, courts and national security authorities of the foreign jurisdiction.

Accuracy: We will make reasonable efforts to ensure your Personal Information is accurate, complete and up to date as necessary for the purposes described in this Privacy Policy.

Retention & Disposal: We retain your Personal Information only for as long as necessary to fulfill our purposes described in this Privacy Policy or as required or permitted by applicable law.

Aggregated & Anonymized Data: We may aggregate and anonymize Personal Information and use, disclose or retain it without restriction.

Access & Update: You may write to us and request access to your Personal Information. We will update your Personal Information as appropriate.

Complaints: We will investigate all complaints made with respect to our compliance with privacy laws.

California’s Shine the Light Law: California residents with an established business relationship with us can request information once a year about sharing their Personal Information with third parties for the third parties' direct marketing purposes.

California Privacy Rights for Minor Users: California residents under the age of 18 who are registered users of online sites, services or applications may request and obtain removal of content or information they have publicly posted.

Hyperlinked Websites: Our website may contain hyperlinks to third party websites, which are not subject to this Privacy Policy.

Changes to this Privacy Policy: We may update this Privacy Policy from time to time and will post the revised Privacy Policy on our website.

Contact Us: You may contact our Privacy Officer using the contact information at the end of this Privacy Policy.

Collecting Your Personal Information

We may collect Personal Information about you, your business and your online activities when you visit our website, use our software and services, interact with us in person, by telephone or by email, SMS, or other electronic means, or interact with social media.

We limit the amount and type of Personal Information we collect to that which is necessary for our purposes. We do not target or knowingly collect Personal Information from persons under the age of majority. .

The types of Personal Information we collect about you include but are not limited to the following:

  • Name & Contact Information: we may collect your first and last name and your contact information such as your address, phone number(s) and email address(es) for the purposes of identifying you, communicating with you, responding to your requests and inquiries and registering your account with us.

  • Cookies & Web Tracking Data: we may collect automatically certain data when you visit our website or use our software including but not limited to the following:

    • Network and connection information such as your Internet Protocol (IP) address, the general geographic location associated with your IP address (known as IP geolocation) and information about your Internet service provider.

    • Computer and mobile device information such as device, application, browser type and version, browser plug-in type and version, operating system or time zone setting.

    • Authentication ad security credential information.

    • Content interaction information such as content downloads, streams and playback details including duration and number of simultaneous streams and downloads.

    • The full Uniform Resource Locators (URL) clickstream to, through and from our website and our software, the date and time of your visit, content you viewed and searched for, page response times, download errors, and page interaction information such as scrolling, clicks and mouse-overs.

  • Payment Information: we may collect certain payment information including payment method, bank account information and credit card information for the purposes of processing your payment for the software and services that you procure from us.

  • Business Data: we may collect certain business data when you use our software or services including but not limited to your current and historical product sales and service transactions, inventory, manufacturer and third party data, data contained in your Dealer Management System (DMS), data regarding your personnel and their performance, your calendar of appointments for product sales and service and your overall business performance. Some business data may constitute Personal Information. We collect business data for the purposes of delivering and maintaining our software and services including our website.

  • Client Performance, Feedback, Reviews & Testimonials: we may use your name, the fact that you have procured our software and services, the details of any improvement in the performance of your business as a result thereof, and your verbal or written feedback or reviews of our software and services for our marketing purposes. We may collect from you also written testimonials regarding your use of our software and services for our marketing purposes including but not limited to display on our website.

  • Social Media Content: if you connect or interact with us using your third party social media account (Facebook, Twitter, Instagram etc.), we may collect certain information about you from your social media content including but not limited to your username, profile picture, preferences, likes, dislikes, posts, messages and friend lists. The information we collect depends on your privacy settings for your applicable social media account.

Using Your Personal Information

We may use your Personal Information as follows:

  • for all the purposes described above;

  • to deliver and maintain your account with us;

  • to deliver, maintain and improve our software and services (including but not limited testing, data analysis and troubleshooting);

  • to analyze your business operations and evaluate its performance;

  • to deliver and maintain our website, monitor its usage and improve its functionality and user experience;

  • to protect against theft, fraud, cyberattacks or similar risks and to improve our security;

  • to communicate with you regarding our software and services that you procure from us including but not limited to their functionalities and providing you with security and other updates related thereto;

  • to provide you with news, special offers and general information about our software and services and events, unless you have opted not to receive such information;

  • to comply with and enforce the terms of our agreements and resolve any disputes between us; and

  • for any purpose permitted or required by law.

Sharing Your Personal Information

We may share your Personal Information with the following persons or in the following situations

  • our employees, parent company, affiliates, subsidiaries, licensors and partners;

  • our third-party service providers who act on our behalf to store or process Personal Information, send communications or conduct marketing;

  • when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud or respond to a law enforcement request; and

  • as required or permitted by applicable law such as pursuant to a subpoena, government inquiry, litigation, dispute resolution or similar legal process.

Except as stated in this Privacy Policy, we will not share your Personal Information with any person without your prior consent.

Consent

The manner in which we obtain your consent to collecting, using or disclosing your Personal Information varies depending upon its sensitivity and applicable privacy law. We may ask for your consent directly or imply your consent through your conduct when it is appropriate for us to do so. In certain situations, when legally permissible for us to do so, we may collect, use or disclose your Personal Information without your consent.

We will honour any specific consents you provide to us and you may withdraw your consent at any time subject to legal and contractual restrictions and by providing us reasonable notice. If appropriate, we will notify you of any implications of withdrawing your consent.

We will not, as a condition to the supply of our software or services, require you to consent to the collection, use or disclosure of your Personal Information beyond that which we require for our purposes.

Choices

You may choose whether to receive electronic marketing messages from us by opting in when given the choice or following the unsubscribe instructions in email or SMS marketing messages that you receive from us.

We cannot block cookies. You must configure your browser settings to block all cookies from our domain. Please see the Cookies & Tracking Technologies section below for details.

Cookies & Tracking Technologies

We use cookies and other similar tracking technologies to automatically track your activity on our website and our software, provide you with a more personal experience such as remembering your account login details and language preference, and for the other uses outlined above

Cookies are small files that are placed on your computer or mobile device by a website and that contain details about your browsing history on that website. Some cookies are deleted at the end of your browsing session while others persist between sessions. Tracking technologies used are beacons, tags and scripts to collect and track information and to improve and analyze our website. Some cookies and tracking technologies are essential to our software such as those used to authenticate you and prevent misuse of your account.

You may configure your web browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some parts of our website or our software and your experience on our website or our software may be hindered.

We use third party analytics services including Google Analytics to create reports and statistics on visits to our website and use of our software. For information on how Google Analytics collects and processes your data, please see “How Google uses data when you use our partners’ sites and apps” located at https://www.google.com/policies/privacy/partners/.

Safeguards

We protect Personal Information against loss, theft and unauthorized access or disclosure by using reasonable technological, administrative and physical security measures that are appropriate to the sensitivity of the Personal Information within our possession or control. These measures include using encryption protocols and software, training our staff on the importance of maintaining the confidentiality and security of Personal Information and requiring our third party service providers acting on our behalf to enter into written agreements with us that require them to secure the Personal Information we share with them.

International Transfers

We transfer your Personal Information outside of Canada including but not limited to the United States of America for storing or processing by our third party service providers for some or all of the purposes described in this Privacy Policy. While we use contractual and other means to ensure your Personal Information is protected while in the foreign jurisdiction, it may be still accessible to law enforcement agencies, government agencies, courts and national security authorities of the foreign jurisdiction.

If you have any questions about our policies and practices regarding our service providers outside of Canada, please contact our Privacy Officer using the contact information at the end of this Privacy Policy.

Accuracy

We will make reasonable efforts to ensure your Personal Information is accurate, complete and up to date as necessary for the purposes described in this Privacy Policy. This includes your Personal Information that is shared with third parties or that is used to make a decision about you. Our reasonable efforts include communicating with you to correct information when we believe it has been incorrectly provided.

Retention & Disposal

We retain your Personal Information only for as long as necessary to fulfill our purposes described in this Privacy Policy or as required or permitted by applicable law. Once no longer required, we will anonymize or destroy your Personal Information.

When determining retention periods, we consider certain criteria including the following:

  • whether the purposes for which your Personal Information was collected have been fulfilled;

  • whether anonymizing or destroying your Personal Information will impact the software or services procured by you;

  • whether your Personal Information has been used to make a decision about you in which case we will continue to retain that Personal Information for at least one year after using it to make the decision to reasonably allow you time to access that Personal Information and to exhaust any access request or challenge you may wish to bring under applicable privacy law; and

  • retention periods required by law.

Aggregated & Anonymized Data

We may aggregate and anonymize Personal Information within our possession or control and use, disclose or retain it without restriction including but not limited to enhancing our software and services, developing new products and services or for our marketing purposes.

Accessing & Updating Your Personal Information

You have a right to access your Personal Information within our possession or control. Upon receiving a written access request from you and upon verifying your identity, we will inform you of the existence, use and sharing of your Personal Information and provide you with access to it. We will respond to your written access request within 30 days or inform you if we require additional time to respond. We may charge you a minimal handling fee. In certain situations, it may be legally permissible for us to refuse your access request and, upon your request, we will provide you with an explanation for the refusal.

You may question the accuracy and completeness of your Personal Information and request that amendments be made to it as appropriate. If you demonstrate in a reasonable manner the inaccuracy or incompleteness of your Personal Information, we will amend your Personal Information as required. If a request is not resolved to your satisfaction, we will record the substance of the unresolved request. Where appropriate, your amended Personal Information or the existence of the unresolved request will be transmitted to the third parties with whom we’ve shared your Personal Information in question.

To make a written access request for your Personal Information, please contact our Privacy Officer using the contact information at the end of this Privacy Policy.

Complaints

Upon your request, we will provide you with information regarding our procedure for addressing any complaints made with respect to our compliance with privacy laws. We will investigate all written complaints and, if we find a complaint to be justified, we will take the appropriate measures including, if necessary, amending our policies and practices.

Your California Privacy Rights (California's Shine the Light law)

Under California Civil Code Section 1798 (California's Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Information with third parties for the third parties' direct marketing purposes

If you'd like to request more information under the California Shine the Light law, and if you are a California resident, please contact our Privacy Officer using the contact information at the end of this Privacy Policy

California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)

California Business and Professions Code section 22581 allow California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.

To request removal of such data, and if you are a California resident, please contact our Privacy Officer using the contact information at the end of this Privacy Policy and include the email address associated with your account.

Please be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

Hyperlinked Websites

Our website and software may contain hyperlinks to websites that are not operated by us and therefore not subject to this Privacy Policy. If you click on a third party link, you will be directed to that third party’s website. We advise you to review carefully the privacy policy of every third party website you visit. We have no control over the privacy policies and practices of these third parties.

Changes to this Privacy Policy

We periodically review our privacy policies and practices to ensure they are relevant, up to date and comply with applicable privacy law. Accordingly, we may update this Privacy Policy from time to time and post the revised version on our website. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective and binding on you when they are posted on our website.

Contact Us

If you have any questions or concerns about this Privacy Policy, please contact our Privacy Officer at:

Privacy Officer
Core Dealer Services, Inc.
4800 Dundas St. W., Suite 207
Etobicoke, Ontario
M9A 1B1
Telephone: 1 (800) 820-7275
privacy@coredealerservices.com