DEFINITION AND SCOPE

Thank you for visiting m.vwst-hyacinthe.qc.ca (the “Website”), provided to you by Volkswagen St-Hyacinthe (“We”). We respect the privacy of every individual who visits the Website and are sensitive to privacy issues on the Internet. We believe it is important that you know how we deal with information received about you.

This privacy policy (the “Privacy Policy”) explains how we collect, use, disclose, and protect the personal information of our customers and Website users ("you"), describes the types of information we may collect from you or that you may provide to us, and our practices for collecting, using, maintaining, protecting, and disclosing that information. We do not knowingly collect personal information directly from children under the age of 13; the Website is for general audiences and is not specifically targeted to or intended for use by children.

We will only use your personal information in accordance with this Privacy Policy unless otherwise required by applicable law. We take steps to ensure that the personal information that we collect about you is adequate, relevant, not excessive, and used for limited purposes. Privacy laws in Canada generally define "Personal Information" as any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person.

By accessing or using the Website, you are accepting the practices described in this Privacy Policy, and you are consenting to our processing of your information as set out in this Privacy Policy. We may modify or update this Privacy Policy from time to time; if we change this Privacy Policy in a manner that materially impacts your privacy rights, we will provide a notice to you. Your continued use of the Website or our services after any modification to this Privacy Policy will constitute your acceptance of such modification. However, when required by law, we will confirm your consent to the revised Privacy Policy terms. This Privacy Policy is incorporated into and considered a part of the Website Terms and Conditions of Use, located at m.vwst-hyacinthe.qc.ca/en/terms-of-use.

WHAT INFORMATION WE COLLECT

We collect and use several types of information from and about you, including:

HOW WE COLLECT THE INFORMATION

Information You Provide to Us

The information we collect directly from you may include:

Information We Collect While You Interact With Us Through Cookies and Other Automatic Data Collection Technologies

The technologies we use for this automatic data collection may include:

Information We Collect About You From Third Parties

We may receive Personal Information about you from various third parties and public sources, such as credit card issuers, financial partners and data analytics firms. We may collect information about you in connection with investigations into fraudulent or criminal activities on the Website and in our stores. We may also collect information from other sources, including for example, joint marketing partners, data analytics firms, public databases, publicly available social media pages, and other third parties we work with.

Information We Create Ourselves

We may aggregate and/or anonymize Personal Information so that it will no longer be considered personal information. We do so to generate other data for our use, which we may use and disclose for any purpose. For example, we may calculate the percentage of our site users who have a particular telephone area code.

HOW WE USE YOUR INFORMATION

We use your information, including your Personal Information, to manage our business and to maintain and develop commercial relationships with you. We will collect, use, and disclose such information only to the extent that is necessary for those purposes.

We use information that we collect about you or that you provide to us, including any Personal Information:

Your Personal Information is also accessible to our employees or representatives who require it in the performance of their duties. Employees or representatives must maintain the confidentiality of your Personal Information at all times, and are required to undergo regular training and awareness-raising activities on security and the protection of personal information.

HOW WE SHARE YOUR INFORMATION

We will not rent or sell your information to third parties without your consent. We only share your data as specifically provided into this Privacy Policy.

Sharing With Our Partners

We may provide your data, including your Personal Information, to our affiliated companies and brands, to third parties who provide services to you or us, such as Solutions Medias 360 Inc., who developed and operates this Website, to promotional partners, to social media companies, or to other third parties as needed to carry out our business, or comply with a legal obligation.

We may share, as the case may be and only after having obtained your prior authorization, certain information about you with the manufacturer or any financial institution involved in your acquisition of a vehicle. Please note that each such establishment sets forth its own privacy policy and we disclaim any liability relating to such policies.

Other Disclosures

In addition to any disclosure you may have consented to or permitted under the terms of this Privacy Policy, we may transfer your data, including Personal Information to third parties in the following limited circumstances: 1) information you expressly consent to be shared; 2) when relating to anonymized information (individuals cannot be identified by it); 3) when you decide to make the information indexable by search engines, to share or to distribute the information to people or otherwise to make it available to the public; 4) to satisfy any applicable law, regulation, legal process or enforceable governmental request within or outside your country of residence when we have a good faith belief that the law requires it; 5) to enforce this Privacy Policy, the Terms, or an agreement, including investigation of potential violations thereof; 6) to detect, prevent, or otherwise address fraud, security or technical issues, or protect the operations or you; 7) to protect our rights, property or safety as well as yours, the public, or others; 8) in connection with an acquisition, merger, change in control, debt financing, reorganization, sales of assets, bankruptcy or other change of our’ corporate structure or status; or 9) as necessary in connection with the performance of requested services or solutions, or as otherwise appropriate in connection with a legitimate need.

HOW WE STORE AND SECURE YOUR INFORMATION

Information Security.

We are committed to protecting the confidentiality, integrity, availability and privacy of your Personal Information. We have put appropriate physical, technological and procedural security measures in place designed to help prevent your Personal Information from being lost, used, modified or accessed in an unauthorized way, or improperly disclosed. Examples of such measures include restricted access to offices, training of personnel, using passwords and well-defined internal policies and practices. We also use encryption technology and Secure Socket Layers ("SSL") in all areas of the Website where your personal account information is required, which means the Personal Information you submit to us via the Website is encrypted by your computer and decrypted again on our side. Your personal account information and transaction history are kept behind a firewall.

In addition, we limit access to your Personal Information to those employees, agents, contractors and other third parties who have a business need-to-know. They will be required to process your Personal Information only on our instructions and they are subject to an obligation of confidentiality. Our service providers are required to maintain adequate security protections in place designed to help safeguard your Personal Information and are not permitted to use it for any purpose other than fulfilling services to us.

Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. Any transmission you provide is at your own risk. Once we have received your information, we will apply our security practices to try to prevent unauthorized access, use and/or disclosure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the “How to contact us” section below.

Information Retention.

We will retain your Personal Information for as long as it is needed: 1) to provide the products and services that you have requested; 2) to communicate with you about a purchase or a request you have made to us; 3) to manage your choices and rights you have exercised pursuant to this Privacy Policy; 4) to enable you to maintain an account with us; 5) to comply with our legal and regulatory obligations and to demonstrate compliance, 6) to resolve disputes and to enforce our rights and agreements.

We may retain non-personal information that has been sufficiently aggregated or anonymized for a longer period.

Once the retention period is over, we will dispose of your Personal Information as provided for in our internal data retention and disposal policy.

Communications outside Quebec

By providing us with Personal Information, you understand that it may be communicated to or stored outside Quebec or Canada by us or one of our suppliers or partners.

In such cases, we will ensure that your Personal Information is adequately protected, in particular with respect to generally accepted principles of protection that are reasonable in the circumstances.

ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION

It is important that the personal information we store about you is accurate and current. Please keep us informed if your personal information changes. By law you have the right to request access to and correct the personal information that we store about you.

You can review and change your personal information by logging into the Website and visiting your account profile page.

If you want to review, verify, or correct the use of your personal information, you may also contact us in accordance with the “How to contact us” section below.

We may request specific information from you to help us confirm your identity and your right to access, as well as to provide you with the personal information that we store about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we store about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

WITHDRAWING YOUR CONSENT

Where you have provided your consent to the collection, use, and transfer of your personal information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us in accordance with the “How to contact us” section below. Please note that if you withdraw your consent, we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision.

We also provide an opportunity for any user to unsubscribe from our email communications or opt-out of contact for marketing or informational purposes on an ongoing basis using the unsubscribe mechanism at the bottom of our emails.

OTHER WEBSITES AND SERVICES

This Website contains links to other websites. They are provided for reference purposes only and may have practices and policies of confidentiality that are different from ours. We are not responsible for, and this policy does not address, the privacy practices of these other third parties, such as Volkswagen, XTime, Facebook, Apple, Google, Microsoft, or any other app developers or social media platforms. If you wish to use one of these services, your personal information will be collected by such third party and will be subject to the third party’s privacy policy. Please check the privacy policies published on any third-party sites which you may access through the Website before submitting Personal Information to them. We have no control over, and are not responsible for this third party’s collection, use, and disclosure of your personal information.

GOVERNING LAW

The Website is operated from Montreal, Province of Quebec, Canada by Solutions Medias 360 Inc. on behalf of Volkswagen St-Hyacinthe. Any conflict between you, us or Solutions Medias 360 Inc is therefore subject to the laws applicable in the Province of Quebec and the applicable laws of Canada. Furthermore, you hereby agree to submit to the exclusive jurisdiction of the courts of the Province of Quebec in respect of any action or proceeding arising out or related to the Website.

COMPLAINTS

Reception

Any person wishing to make a complaint concerning the application of this policy or, more generally, the protection of his or her Personal Information, must do so by writing to the Privacy Officer at the e-mail address indicated below.

The individual must provide his or her name, contact information, including a telephone number, as well as the subject of the complaint and the reasons for it, giving sufficient details to allow the complaint to be evaluated. If the complaint is not specific enough, the Privacy Officer may request any additional information he or she deems necessary to assess the complaint.

Treatment

We undertake to treat all complaints received confidentially.

Within 30 days of receipt of the complaint, or of receipt of any additional information deemed necessary and required by the Privacy Officer in order to process the complaint, the Privacy Officer shall assess the complaint and provide a reasoned written response by email to the complainant. The purpose of this assessment will be to determine whether the processing of personal information complies with this Privacy Policy, any other policies and practices in place within the organization, and applicable legislation or regulations.

If the complaint cannot be processed within this timeframe, the plaintiff must be informed of the reasons for the extension, the status of the complaint and the reasonable time required to provide a definitive response.

You may also file a complaint with the Commission d'accès à l'information du Québec or any other privacy oversight body responsible for enforcing the law relating to the subject of the complaint.

However, we invite anyone interested to first contact the Privacy Officer and wait until the processing is complete.

HOW TO CONTACT US

We welcome your questions, comments, and requests regarding this privacy policy and our privacy practices. Please contact us at:

Chief Privacy Officer Contact Details:

Annie Fafard

5705 Avenue Trudeau,

Saint-Hyacinthe, Quebec,

J2S 1H5

Volkswagen St-Hyacinthe

Telephone:450-773-9643

Email: afafard@vwsh.ca

We have procedures in place to receive and respond to complaints or inquiries about our handling of personal information, our compliance with this policy, and with applicable privacy laws. To discuss our compliance with this policy please contact our Privacy Officer using the contact information listed above.

UPDATES

This document may be updated on a regular basis in line with legislative, technological and organizational developments.

Current version: October 4, 2023.