Canadian Dealer Lease Services Inc. (“CDLSI”) is committed to protecting the confidentiality and integrity of its customers’ personal information. This document (the “Policy”) describes the collection, retention, use, and disclosure of CDLSI customers’ personal information. By providing us with your personal information, either through a lease application or otherwise, you agree to our use of your personal information as described in this Policy.
Our Relationship with Your Dealer and Scotiabank.
CDLSI administers leasing programs financed by Scotiabank (the “Lender”) and which are facilitated through car dealerships. Any information (including personal information) you provide to your dealer in connection with your lease application will be shared with CDLSI. To evaluate your eligibility and administer your participation in one of our leasing programs, all personal information which CDLSI has will be made available to the Lender. Specific disclosures of personal information made by CDLSI are described in greater detail below under the heading "Disclosure of Personal Information".
1. PERSONAL INFORMATION WE COLLECT
What is Personal Information?
“Personal Information” consists of information about an identifiable individual, including name, address, date of birth, vehicle information, lease status (such as the amount owing and whether the lease is in default) and financial information. The use of masked anonymous information or aggregated information is outside the scope of this Policy as is information about corporate entities.
Where do We Obtain Your Personal Information?
Your Personal Information is initially collected by your dealer when you apply for a vehicle lease. We will supplement this Personal Information with additional information you provide directly to us and with information provided by third parties such as credit bureaus. If you elect to participate in our leasing programs, your Personal Information may be further supplemented by information arising in connection with such participation, including information from the Lender and from your dealer.
Why do We Collect Personal Information?
We only collect your personal information for the following purposes:
- to determine your eligibility for any of our leasing programs;
- to administer and manage your participation in our leasing programs, including assisting the Lender in connection with the related financing;
- to communicate with you in connection with your evaluation of or participation in our leasing programs or otherwise to respond to your questions or concerns;
- to ensure compliance with leasing program requirements including proper insurance coverage; and
- to facilitate and administer your relationship with us, the Lender, your dealer and the car manufacturer.
What Personal Information Do We Collect?
We only collect Personal Information that is reasonably necessary in connection with your application and evaluation for a leasing program and, if applicable, the administration of your participation in such leasing program. In connection with the foregoing, we will collect the following information:
- name (including your middle name)
- current and potentially former address
- years at address
- whether you own or rent
- your home and other telephone numbers
- date of Birth
- current Employer
- years at current employer
- business telephone number
- gross monthly income
- banking account information
- information you provide on the Customer Identification Verification Form and/or your Drivers’ License Information, including
- ID Reference Number
- place of Issue
- expiration Date
- credit history and related information
- proof of vehicle insurance that meets the requirements of the leasing program
- information you otherwise provide in your application or communications to us
2. HOW DO WE USE YOUR PERSONAL INFORMATION?
Your Personal Information is only used in connection with the purposes of which it was collected described above under the heading “Why Do We Collect Personal Information?” Some specific examples of how it may be used include:
- communicating with you, the Lender, your dealer and the car manufacturer regarding your lease program, including sending you related information and other notices;
- corresponding with you to respond to a question;
- investigating a complaint;
- ensuring proper insurance coverage;
- to collect payments; and
- on behalf of the dealer or the car manufacturer, we may send you promotional or related information leading up to the maturity of your lease
If Personal Information is used for any purpose not specifically identified in this Policy, it will be communicated to you (or will be implicit) at the time you provide the related Personal Information to us. An example of this would be the provision of additional Personal Information to participate in a promotion which we offer or administer.
3. SHARING AND DISCLOSING YOUR PERSONAL INFORMATION
Disclosure of Personal Information
CDLSI will not share, sell, rent, or trade Personal Information. CDLSI will only disclose Personal Information as described in this Policy. As noted above, we will share all Personal Information with the Lender. Some Personal Information will be shared with the dealership and car manufacturer – this information generally relates to lease maturity dates. We also disclose Personal Information to the following recipients:
- Our insurance providers. We share Personal Information with our insurance providers regarding lessees who we determine do not have sufficient insurance coverage in order to obtain additional insurance on those vehicles. We also share personal lessee information with our insurers regarding vehicles that have been stolen or involved in incidents in which the vehicle is written off.
- Lessee primary insurance providers. We share Personal Information with lessees’ primary insurance providers in connection with any claims we need to make or as required for the purposes of maintaining your/our insurance.
- Ancillary insurance holders. We share personal information with providers of ancillary insurance products (such as extended warranty, life and disability, wear care etc.) for the purpose of registering, cancelling, extending, or making claims related to these insurance products.
- Independent third-party inspection companies. We share personal information with third-party inspection companies to enable them to contact you to arrange an inspection on your vehicle during the final weeks of your lease.
- Vehicle remarketing companies. We share personal information with vehicle remarketing companies which supply the vehicle grounding tools to ensure that your information is available to your dealer when you return your vehicle to the dealership.
- Your vehicle manufacturer, to whom we provide your contact information – which they may use to communicate with you regarding the lease or for other purposes related to your business relationship
- If you fail to make timely payments, your Personal Information may be provided to our third-party collection companies
- Some of your Personal Information will be provided to our third-party insurance tracking company to confirm your insurance coverage
- Credit bureaus may receive additional Personal Information from us regarding our relationship with you
- Other entities such as the Canada Revenue Agency, the Police and other similar bodies as required by law
- Our other service providers who we may utilize in connection with the administration of your lease program. Our use of service providers is further discussed below under the heading “Service Providers”.
Financings: Sale of Business
In addition to the disclosures mentioned above, Personal Information may also be disclosed in connection with a reorganization, acquisition, divestiture or financing, including disclosures to:
- successor corporations;
- lenders; or
- a proposed acquiror of the business or a division of the business of CDLSI
Any entity that obtains Personal Information in connection with a reorganization, acquisition, divestiture or financing shall be bound by the obligations and protections provided by CDLSI under this Policy.
From time to time, CDLSI may use service providers in connection with its administration and delivery of the leasing programs (the "Third Party Service Providers"). We use Third Party Service Providers to efficiently deliver our services to you and we disclose your Personal Information to Third Party Service Providers solely as needed to permit their delivery of services to us and our affiliates. These Third Party Service Providers may only use and store your Personal Information to provide us with a specific service and not for any other purpose. In addition, we will use contractual or other means to provide a comparable level of protection while the Personal Information is in the possession of these Third Party Service Providers. You can obtain information about our policies and practices with respect to Third Party Service Providers or otherwise obtain information regarding the collection, use, disclosure or storage of Personal Information by our Third Party Service Providers by contacting us as described below under the heading “Accessing Your Personal Information and Contacting Us”.
4. STORING PERSONAL INFORMATION
Your Personal Information may be stored and processed by us or our Third Party Service Providers within or outside of Canada, including in the United States or elsewhere in the world. Due to the nature of digital information, your Personal Information may be stored and processed by us or our Third Party Service Providers in a number of different jurisdictions throughout the world and is subject to the disclosure laws of such jurisdictions. While the laws protecting Personal Information in these other jurisdictions may not be as comprehensive as those in Canada, please be assured that we take reasonable steps to ensure that your Personal Information is always protected.
5. PROTECTION OF PERSONAL INFORMATION
CDLSI’s employees and service providers who have access to Personal Information shall only be permitted to access such Personal Information as necessary to enable them to perform their duties. With the exception of the Lender, the only other parties with whom CDLSI staff may discuss Personal Information are the lessee, co-lessee, dealer, car manufacturer or insurer, and only after the identity of such individuals has been verified. CDLSI employs a number of physical, technological, and organizational safeguards to protect Personal Information against accidental or intentional manipulation, loss, destruction, or access by unauthorized persons.
Organizational measures include:
- requiring all physical documentation containing Personal Information to be shredded as soon as it is no longer needed;
- requiring all physical documentation containing Personal Information to be stored in a filing room or a filing cabinet that gets locked nightly;
- providing training and educational programs to educate staff about the meaning and requirements of this Policy and CDLSI’s security policies, including:
- a comprehensive information security policy which is readily available to staff and on which staff have been trained. This includes on-site computer protections, network security; general IT security measures and obligations regarding physical files and documents;
- a comprehensive premises access and security obligations policy to protect Personal Information which is either physically onsite or is accessible onsite; and
- a clean desk policy to ensure that working space is maintained in a condition that will significantly reduce the likelihood of unauthorized disclosure of Personal Information.
Staff are trained on, and are expected to observe the foregoing policies which are enforced by CDLSI.
CDLSI has a record retention policy under which it maintains records of Personal Information for only as long as necessary and then destroys those records in a secure manner by authorized personnel once those records are no longer needed.
6. ACCESSING YOUR PERSONAL INFORMATION AND CONTACTING US
CDLSI is committed to protecting customers’ Personal Information and ensuring that it is kept up-to-date, accurate, and complete as necessary for the purposes identified above. Customers may contact CDLSI for the purposes of accessing and rectifying their Personal Information in any of the following methods:
Fax: (416) 703-9208
In order to access or rectify Personal Information, customers will be required to verify their identities. If CDLSI’s record of Personal Information is inaccurate or incomplete, customers may request updates or corrections.
Our Privacy Officer is responsible for our compliance with this Policy and all applicable privacy legislation. If you
- have any questions about our privacy practices or any of the terms or conditions of this Policy,
- have any questions about the collection, use, disclosure or storage of Personal Information by our Third Party Service Providers located outside of Canada, or
- wish to access written information about the policies and practices utilized in connection with our Third Party Service Providers use of Personal Information outside of Canada,
- have any concerns or complaints regarding your Personal Information,
Please contact our Privacy Officer in any of the following methods:
Fax: (416) 703-9208
Change in Policy
This Policy updates and replaces any previous policy customers may have received from CDLSI in the past. CDLSI reserves the right to change this Policy at any time. Unless you otherwise consent, any such change will only impact how CDLSI uses and discloses Personal Information collected after such update. All Personal Information otherwise in CDLSI’s possession will only be used and disclosed for the purposes identified in this Policy at the time such Personal Information was collected.
Legal and Regulatory Disclosure
CDLSI shall disclose Personal Information to the extent required in any legal proceeding or by any court order and reserves the right to release any Personal Information which is appropriate to protect itself from fraud or other harm, to enforce its contractual rights against customers, or otherwise protect the rights, property, or safety of the company, customers, and others.
CDLSI maintains a policy of cooperation with the CRA and will provide Personal Information to the CRA upon its request. CDLSI also cooperates with law enforcement and will provide Personal Information to law enforcement officials upon receipt of a court order to do so.