Subaru Canada, Inc. (“Subaru”) values its relationship with
you, our existing or potential customers, suppliers, employment
applicants,
dealers and partners, and is committed to maintaining the security, confidentiality
and privacy of your personal information. Subaru has developed a Personal
Information Privacy Policy incorporating the principles set out below,
to reflect its on-going commitment to you. Subaru has ensured that its
Privacy Policy is in compliance with Canadian privacy laws which apply
to the collection, use and disclosure of personal information.
“Personal Information” as used in this Privacy Policy means
information about an identifiable individual. This Privacy Policy does
not apply to the collection, use or disclosure of business contact information
(for example the name, title, business address and telephone number of
an employee of an organization), to Subaru’s employees, or in part
to certain publicly available information.
Accountability for Subaru’s compliance with its Privacy Policy rests with Subaru’s Privacy
Officer, even though other individuals within Subaru may have
responsibility for management of personal information or may be delegated
to act on behalf of the Privacy Officer.
Subaru will be responsible for personal information in its possession
or custody, and will also use contractual or other available means to
provide a comparable level of protection when the information is being
processed or managed by a third party on Subaru’s behalf.
In general, Subaru has collected, and will continue to collect, use and disclose personal information for purposes authorized or required by law, as well as for the following purposes:
- to maintain accurate customer records to satisfy legal and industry-wide regulatory obligations (for example, notification of service campaigns and recalls)
- to fulfil individual customer service and warranty-related
needs
- to establish and maintain communications with you relating to our existing, past or future relationships, and our products and services, including responding to your inquiries
- to conduct surveys which help Subaru identify ways to better manage
its business and provide products and services
- to distribute Six Star Review, The Magazine for Canadian Subaru
Owners and similar Subaru magazines and publications
- to provide you with information about products and services related to the maintenance of your vehicle and new product offerings
- to allow you to participate in Subaru vehicle test drives
- to receive communications from Subaru about special offers made jointly with C.A.R.Efully selected industry partners (all correspondence of this nature is conducted or directly managed by Subaru)
- to share some of your information under strictly limited
and confidential circumstances with our affiliates, dealers, representatives,
suppliers and Subaru business partners such as the Canadian Automobile
Association (CAA) who assist us in providing products and services
and allow us to more effectively carry on our business
- to establish, administer and document training, development
and educational requirements and programs
- to establish, administer and document incentive programs
- to evaluate potential suppliers and their staff, make decisions
about entering into product and/or supply relationships with them,
and to monitor, assess and address these relationships
- to evaluate potential dealers and their staff, make decisions
about entering into dealer relationships with them, and to monitor,
assess and address these relationships
- to evaluate potential partners and/or co-suppliers and their
staff, make decisions about entering into relationships with them,
and to monitor, assess and address these relationships
- to evaluate potential employees and make decisions about
hiring (including employment history, reference checks, academic history
and medical evaluations)
- to implement and manage security programs and internal controls
(including computer monitoring and video surveillance)
- to protect Subaru, and its customers, suppliers, dealers
and partners, from theft, fraud and similar risks
Unless applicable privacy laws provide otherwise, Subaru will make a
reasonable effort to specify the identified purposes in a readily understandable
way to the individual from whom the personal information is being collected,
either at the time of collection or after collection but before its use
or disclosure.
The way in which Subaru obtains your consent to collecting, using or
disclosing your personal information will vary depending upon its sensitivity.
An individual can withdraw consent at any time, subject to legal or
contractual restrictions, by giving to Subaru reasonable notice. In
appropriate cases, Subaru will inform individuals of any implications
of withdrawing consent. Subaru will not, as a condition of the supply
of services, require an individual to consent to the collection, use,
or disclosure of personal information beyond that required to fulfil the specified purposes.
In certain circumstances as permitted or required by law, Subaru may
collect, use or disclose personal information without the knowledge or
consent of the individual. These circumstances include the following:
to investigate a breach of an agreement or a contravention of a law;
where collection or use is clearly in the interests of the individual
and consent cannot be obtained in a timely way; personal information
subject to solicitor-client privilege; for debt collection; to act in
respect to an emergency that threatens an individual; or to comply with
a subpoena, warrant or court order.
If you want to change the mailings you are receiving and/or correct
your personal information please click here privacy.mysubaru.ca
Subaru will limit the amount and type of personal information collected
to that which is necessary for our identified purposes. Personal information
will not be used or disclosed for purposes other than those for which
it was collected, except with the consent of the individual or as required
by law. Personal information will be retained only as long as necessary to
fulfil the identified purposes, and will be destroyed or made anonymous
as soon
as reasonably possible after the original purpose is no longer served
by the retention of the information, provided the personal information
no longer required for legal purposes. Personal information which has
been used to make a decision about an individual will be retained long
enough to reasonably allow the individual access to the information
after the decision, and long enough to exhaust any access request
or a challenge
an individual may bring under applicable privacy laws.
All individuals generally have a right to access their personal information
in Subaru’s possession or custody. Upon receiving a written request (mail,
e-mail or fax) addressed to Subaru’s Privacy
Officer clearly identifying the requested information with adequate
identification of the requesting individual, Subaru will inform the individual
of the existence, use, and disclosure of the personal information and
give the individual access to that personal information. If Subaru is
not able to provide a list of the organizations to which it may have actually
disclosed the personal information, it will provide a list of organizations
to which it may have disclosed the information.
Subaru will respond to an individual’s written access request,
with information in a form that is generally understandable, within a
reasonable time (generally within 30 days) or will provide an explanation
if additional time is required to fulfil the request. While Subaru’s
response will typically be provided at no cost to an individual, depending
on the nature of the request and the amount of information involved,
Subaru reserves the right to impose charges. In such case Subaru will
inform the individual of the approximate cost to provide the response,
and will provide the information upon receipt of payment.
Individuals can question the accuracy and completeness of their personal
information and request that it be amended as appropriate. If an
individual demonstrates in a reasonable manner the inaccuracy or incompleteness
of their personal information, Subaru will amend the information
as
required. If a request is not resolved to the satisfaction of the
individual, Subaru
will record the substance of the unresolved request. Where appropriate,
the amended information or the existence of the unresolved request
will be transmitted to third parties having access to the information
in question.
In some situations, Subaru may be permitted to refuse or not be able
to provide access to certain personal information, and will upon
request provide an explanation. Exceptions to the access right
which are permitted
or required by applicable privacy laws include: information that
contains references to other individuals or contains confidential
commercial
information (where such information cannot be severed from the
record); information
collected in the course of investigating a breach of an agreement
or in the course of a formal dispute resolution process; and information
that is subject to solicitor-client privilege.
If you need to obtain a copy of the form to be
used to make access requests to Subaru for your personal information
which Subaru may hold, please
click here: SCI Access Request Form
Subaru will strive to ensure that the personal information it uses on
an ongoing basis is accurate, complete and up-to-date as necessary
for the purposes for which it is to be used, including information
that is disclosed to third parties, and information that is used to
make a decision about an individual.
Subaru protects the personal information it holds or controls, by establishing
reasonable security arrangements against loss, theft, unauthorized
access, use, disclosure, copying or modification. Subaru will make
its employees aware of the importance of maintaining the confidentiality
of personal information, and will exercise care in the disposal or
destruction of personal information. Examples of safeguards include
physical measures (such as locked filing cabinets and access cards),
organizational measures (such as security clearances and restrictions
on employee access to files and databases) and technological measures
(such as passwords and firewalls).
Subaru will make the following readily available: general information
concerning our Privacy Policy; how to gain access to your personal information;
the type of personal information held by Subaru; a general account of
the use and disclosure of the personal information; and how to contact
our Privacy Officer.
Subaru will, on request, provide information regarding its procedure
for addressing any complaints made with respect to Subaru’s application
of privacy laws. Subaru will investigate all written complaints, and
if it finds a complaint to be justified, Subaru will take the appropriate
measures, including, if necessary, amending our policies and practices.
Please direct any questions about the complaint procedure
or any other aspect of this Privacy Policy to Subaru’s Privacy
Officer at:
Privacy Officer
Subaru Canada, Inc.
560 Suffolk Court
Mississauga, Ontario, L5R 4J7
e-mail at: privacyofficer@mysubaru.ca
Internet: privacy.mysubaru.ca
Telephone: 1-800-894-4212
Fax: 905-568-8087 |
