PEARL Client Privacy Policy

PEARL Client Privacy Policy:

PEARL Club Group and its affiliated companies (collectively “PEARL”) are committed to the protection of your personal information.

This Privacy Policy explains the privacy practices in connection with PEARL’s activities, both online and offline, mobile apps,

as well as in person or telephone interactions. This includes your PEARL Service Contract, the provision of other product and service offerings.

PEARL carries on business as “PEARLCORP” throughout Canada

Policy Contents:

1. Accountability for Your Privacy

2. Personal Information and How We Collect It

3. Using Your Personal Information

4. Withdrawing Your Consent

5. Sharing Your Information

6. Our Website and App Practices

7. Keeping Your Information Safe

8. Accessing Your Personal Information

9. How Long We Keep Your Information

10. External Links and Social Media

11. Our Privacy Complaint and Breach Management Process

12. Changes to this Policy

13. Getting in Touch

1. Accountability for Your Privacy

PEARL takes full responsibility for the management and confidentiality of personal information we collect and use. Personal information is collected, used, shared and stored in accordance with the Personal Information Protection and Electronic Documents Act, S.C. 2000, c.5 and any applicable provincial privacy laws that may apply to PEARL from time to time.

PEARL has an appointed a lawyerr who oversees compliance with privacy laws and best practice. The duties include:

• Developing and, on a regular basis, reviewing the implementation of internal procedures to protect personal information;

• Ensuring all staff are trained on privacy best practices and are aware of the importance of safeguarding any personal information that they are privy to;

• Ensuring that all inquiries and complaints relating to privacy are appropriately handled; and

• Ensuring all third parties to whom PEARL provides access to personal information adhere to appropriate standards of care in handling that information.

2. Personal Information and How We Collect It
‘Personal information’ is any factual or subjective information, recorded or not, about an identifiable individual.

For PEARL Clients, this includes your name, contact information, birthdate, gender, email address, type of vehicle, Service Contract usage, vehicle diagnostics, payment information, any identifiers such as your PEARL Service Contract number, driver’s license or GPS (vehicle location) and any identifiable on-line activity. We also collect information about your PEARL retail purchases and preferences.

Direct Collection
Personal information can be collected directly from you in several ways with your knowledge and consent, or as authorized by law, including through phone calls, electronic messages, application forms, as well as any other documents you provide to PEARL.

Indirect Collection
There are also ways in which PEARL collects personal information indirectly. For example, to obtain an associate Service Contract, PEARL collects personal information about other clients of your household from you, and for auto insurance, you may provide information regarding other drivers of your vehicle. We assume you have obtained consent to our collection, use and disclosure of others’ personal information for the purposes outlined in this policy.

PEARL may collect your personal information from third parties as well. For example, with your explicit consent, a credit reporting agency or previous insurer may provide information to PEARL. PEARL implies or assumes consent only if doing so is reasonable and appropriate based on our relationship with you. For example, we may collect information from a contracted service provider that has provided services in relation to your Service Contract.

Note that there may be instances where the law permits the collection, use or disclosure of your personal information without your consent, for example for debt collection, fraud investigations, and where necessary to protect our legal interests or the safety of others.

3. Using Your Personal Information

We use personal information for the following specific purposes:

• To confirm eligibility for Service Contract or other PEARL products and services.

• To process, administer and manage your PEARL Service Contract (if applicable);

• To provide you with the PEARL products and services you have requested.

• To process, administer and manage your vehicle repairs.

• To better understand your needs and the ways in which we can improve our products and services.

• To verify your identity and to communicate with you, including responding to your inquiries and confirming receipt of a requested product or service.

• To process payments.

• To inform you about products and services that we offer (or that we and our loyalty partners jointly offer), which we believe may be of interest to you.

• To administer your participation in contests or promotions sponsored by PEARL and to contact you if you are eligible to win a prize;

• To conduct surveys or research for PEARL’s internal use in order to better understand our clients and improve our product and service offerings, as well as to compile aggregate statistics for internal reporting purposes;

• To assess and manage risk, including detecting and preventing fraud;

• To collect debts owed to PEARL and enforce agreements between you and PEARL; and

• To meet auditing, legal and regulatory processes and requirements.

4. Withdrawing your Consent

Your consent can be withdrawn at any time, subject to legal or contractual restrictions, by providing us with written notice to the contact information found at the end of this policy. Upon receipt of notice to withdraw consent, we will inform you of the consequences of withdrawing your consent before we process your request, which may include PEARL’s inability to provide you with certain products or services.

If you wish to opt out of receiving marketing or promotional communications from us or change your communications preferences, please email notice of withdrawal to justdrive@pearlcorp.ca or contact us at 1-800-563-1020. If you have received an email from PEARL, you may also click the “unsubscribe” link at the bottom of each of our emails. Please note that if you unsubscribe from receiving marketing communications, you may still continue to receive transactional or informational messages from us.

5. Sharing Your Personal Information

PEARL takes all reasonable steps to protect the interest of individuals when disclosing personal information. We do not disclose personal information for purposes other than those purposes for which it was collected, unless you have provided consent to do so or we are required/permitted by law to disclose the information.

Service Providers and Business Partners
We may share your personal information with business partners, service providers and suppliers of goods and services. For example, we may use third party service providers to authorize and process payments, send email or other communications, process information collected through telematics devices, conduct customer research or manage and analyze data.

Our service providers are only given the information they need to perform their designated functions.

We take reasonable steps to ensure that any third parties who we entrust with your personal information are reputable and have safeguards in place to protect this information.

In working with business partners, service providers and suppliers, your personal information may be transferred to a foreign jurisdiction to be processed or stored. Such

information may be provided to law enforcement or national security authorities of that jurisdiction upon request, in order to comply with foreign laws.

Affiliated Companies
We share your personal information with affiliated companies within the PEARL group of companies. For instance, our Service Contract service agents may see whether you have conducted business with our affiliated warranty companies. This information sharing allows us to offer you client discounts and rewards and to inform you about products and services which we believe may be

of interest to you.

Third Party Advertising
PEARL may also share your name, phone number and e-mail address with third party ad-servers such as social media platforms for targeted advertising purposes. Services such as Facebook Custom Audiences and Google Ads Custom Match allow PEARL to reach potential customers who would benefit from our products and services. Information provided to such third parties is secured at all times and only used for the purpose of displaying ads and reporting back to PEARL on

the performance of such ads. You can choose to hide ads through your socials at any time, or you can contact PEARL to opt out of sharing your information with social media platforms altogether, by sending an email to justdrive@pearlcorp.ca with ‘opt-out social media’ in the subject line.

PEARL also uses third party advertising partners to provide on-line visitors with relevant ads across the Internet. You may also opt out of interest-based advertising by visiting the opt-out tool made available by the Digital Advertising Alliance of Canada at youradchoices.ca/choices.

collected from the device may be provided to third parties in relation to an accident, investigation and/or litigation.

6. Our Website and App Practices

When you use visit PEARL’s websites or use PEARL’s apps, we automatically receive and record information in our server logs from your browser or mobile platform, including the date and time of your visit, your IP address, unique device identifier, browser type and other device information (such as your operating system version and mobile network provider).

PEARL uses “cookies” to identify you as a registered and/or returning visitor. Cookies are files sent from a website to a visitor’s computer which may then be stored on your hard drive so we can recognize you when you return. PEARL uses both session and permanent cookies. This data may be used for statistical purposes and to personalize future visits or communications (via direct mail, email or telecommunications). By setting cookies, PEARL is also able to enhance a user’s on-line experience (e.g. once you are logged in to your account, you are able to move between webpages without having to re-enter your credentials). You can disable cookies through your website browser, but this may affect your

user experience.

The usage data we collect when you visit PEARL’s websites or use PEARL’s apps help us analyze and improve the performance of our digital services. PEARL uses Google Analytics for web statistical analysis. We make no effort to personally identify you based on your visit to our site. If you wish, you may opt out of being tracked by Google Analytics by disabling or refusing third party cookies; by disabling JavaScript within your browser; or by using the Google Analytics Opt-Out Browser Add-On.

7. Keeping Your Information Safe

PEARL has implemented critical physical, organizational and technical measures to guard against unauthorized or unlawful access to the personal information we manage and store. We have also taken steps to avoid accidental loss or destruction of, or damage to, your personal information. While no system is completely secure, the measures implemented by PEARL significantly reduce the likelihood of a data security breach.

Here are some examples of the security controls we have in place:

• Secure office premises;

• Locked filing cabinets and a secure shredding practice for paper records;

• The use of encryption, such as secure portals for document transfers and tokenization for payment card information;

• Robust authentication processes, including complex passwords, for electronic records;

• Limited access to personal information by employees who need the information to perform their work-related duties; and

• The use of data centres with effective physical and logical data security controls.

In addition, we recommend that you do your part in protecting yourself from unauthorized access to your personal information. For example, ensure your PEARL account login credentials are not shared with anyone. PEARL is not liable for any unauthorized access to your personal information that is beyond our reasonable control.

Let us know right away if your contact information changes or you find any errors in your account statements or invoices. If you have reason to believe that the security of your account has been compromised, you must immediately notify

PEARL of the problem in order for us to resolve the issue in a timely manner.

8. Accessing Your Personal Information

We make every effort to ensure that the personal information we hold is accurate, complete and up-to-date for the purposes for which we collect it. You can make a written request for access to your personal information at any time if it is for information that you are unable to access yourself through your PEARL account. You will need to provide as much information as necessary to help us process your request and locate the information you require.

If you need assistance in preparing your request, please contact us and we would be pleased to help you. Upon receipt of your request, PEARL will update your information, or inform you of how your personal information has been or is being used, and who your personal information has been shared with. We may charge a fee to cover any reasonable expenses related to responding to your access request.

PEARL responds to access requests within 30 days, unless an extension of time is required. However, there may be contexts where access is refused or only partial information is provided, for example, in the context of an on-going investigation or where another individual’s personal information or identity must be protected.

9. How Long We Keep Your Information

PEARL retains personal information for as long as necessary to fulfill legal or business purposes and in accordance with our retention schedules. Once your information is no longer required by PEARL to meet business, legal or regulatory requirements, it is securely destroyed, erased or made anonymous. Keep in mind however that information may be retained for a lengthier period of time due to an on-going investigation or legal proceeding, and that residual information may remain in back-ups for a period of time after its destruction date.

10. External Links and Social Media

We may offer links from our website to the sites of third parties, such as partner organizations, that may be of interest to you. PEARL makes no representations as to such third parties’ privacy practices and we recommend that you review their privacy policies before providing your personal information to any such third parties.

PEARL’s use of social media serves as an extension of our presence on the Internet and help us build a positive brand image as well as provide useful information to the public. Social media account(s), such as PEARL’s Facebook and Twitter accounts, are not hosted on PEARL’s servers. Users who choose to interact with PEARL via social media should read the terms of service and privacy policies of these services/platforms.

11. Our Privacy Complaint and Breach Management Process

PEARL takes privacy complaints very seriously and has a procedure in place for escalating and managing any privacy- related concerns to ensure that they are responded to in a timely and effective manner. Any suspected privacy breach must be escalated internally to PEARL’s Privacy Lawyer who oversees the containment, investigation and corrective actions for all breach situations.

As required by law, privacy breaches may be reported by PEARL or its business partners to the regulators of the relevant provinces in which affected individuals reside.

12. Changes to this Policy

We may change this Privacy Policy from time to time in order to better reflect our current personal information handling practices. Thus, we encourage you to review this document frequently. The “Last Updated” date at the top of this Privacy Policy indicates when changes to this policy were published and are thus in force. Your continued use of PEARL products and services following the posting of any changes to this Privacy Policy means you accept such changes.

13. Getting in Touch

Any inquires, concerns or complaints regarding privacy should be directed to:

PEARL Privacy Office

Box 422, 509 Commissioners Rd W., London, Ontario

N6J 1Y5

E-mail: justdrive@pearlcorp.ca

Phone: 1-800-563-1020

Your concerns will receive prompt attention

Thank you for continued trust in PEARL.

PEARL Client Privacy Policy

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