Privacy Statement, Agreement to Receive Electronic Documents, and State-Specific Notices

Rev. 2.2/2014

Facts - What Does Rowley Wilson Auto Sales Do With Your Financial Information?
Why?	Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.
What?	The types of personal information we collect and share depend on the product or service you have with us. This information can include: Your contact information Your business history with us Your Income Account balances and payment history Credit history and credit bureau scores
How?	All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons Rowley Wilson Auto Sales chooses to share; and whether you can limit this sharing.

Reasons we can share your personal information	Does Rowley Wilson Auto Sales Share?	Can you limit this sharing?
For our everyday business purposes—such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus	Yes	No
For our marketing purposes— to offer our products and services to you	Yes	No
For joint marketing with other financial companies?	Yes	No
For our affiliates' everyday business purposes - information about your transactions and experiences	Yes	No
For our affiliates' everyday business purposes - information about your creditworthiness?	Yes	Yes
For our affiliates to market to you?	Yes	Yes
For non-affiliates to market to you?	Yes	Yes

To limit our sharing

Call our Customer Service department Toll Free at 1.888.653.9929
Visit us online at rowleywilson.ca/contact/

Please note:

If you are a new customer, we can begin sharing your information 30 days from the date we sent this notice. When you are no longer our customer, we continue to share your information as described in this notice.

However, you can contact us at any time to limit our sharing.

Questions?

Call Toll Free: 1.888.653.9929 or Online at rowleywilson.ca/contact/

Who We Are
Who is providing this notice?	Rowley Wilson Auto Sales, its parent company, assignees and licensors.
What We Do
How Does Rowley Wilson Auto Sales protect my personal information?	To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards, data encryption, secured files and buildings.
Why can’t I limit all sharing?	Federal law gives you the right to limit only: Sharing for affiliates’ everyday business purposes—information about your creditworthiness Affiliates from using your information to market to you Sharing for non-affiliates to market to you
What happens when I limit sharing for an account I hold jointly with someone else?	Your choices will apply to everyone on your account—unless you tell us otherwise.

Definitions
Affiliates	Companies related by common ownership or control. They can be financial and nonfinancial companies.
Non-affiliates	Companies not related by common ownership or control. They can be financial and nonfinancial companies. Nonaffiliates we share with can include lending institutions named below, their direct and indirect affiliates, as well as other consumer finance companies; financial service providers including insurance companies and motor vehicle dealers and their lending partners; nonfinancial companies such as retailers, aftermarket product providers, co-branded partners, direct marketers, and advertisers.
Joint marketing	A formal agreement between non-affiliated financial and nonfinancial companies that together market products or services to you. Our joint marketing partners include companies such as lending institutions, financial service providers, motor vehicle dealers, insurance companies, aftermarket product providers, co-branded partners, direct marketers, advertisers and retailers.

Your Application Submission

When you complete and submit the application form, you certify that all of the statements in the application are true and complete and are made for the purpose of obtaining credit. You authorize Rowley Wilson Auto Sales to share your application and related information with its lending partner(s) and Finance Lending Institutions in order to complete the processing of your application. You authorize Rowley Wilson Auto Sales, its lending partners and Finance Lending Institutions to retain and rely on your application, to access your credit report in order to evaluate your credit application and to verify the information in your application, including income and employment. In addition, you acknowledge that you agree to receive Electronic Documents. You further authorize Rowley Wilson Auto Sales’s lending partner(s) and Finance Lending Institutions to disclose any credit decision and related credit decision details to Rowley Wilson Auto Sales and other lending partners. By clicking the 'Submit' button at the bottom of the form, you authorize third-party lending institutions and Finance Lending Institutions to share information in your application, and any other credit information they obtain, with other third parties who may be able to offer or arrange for a direct loan and/or dealer financing. Rowley Wilson Auto Sales, it's Financial Lending Institutions and up to five participating dealers, lenders and other third parties may contact me on any number provided, using automated telephone dialing systems, text and/or pre-recorded messages to expedite my request and present other relevant offers. By clicking the submit button, I am consenting to these methods of contact. Consent is not required as a condition of the services.

If at any time in the future you change your mind and wish to remove yourself from our mailing list, simply unsubscribe by clicking on the unsubscribe link at the bottom of our e-mails.

Online Privacy Policy Notice

Last updated June 14, 2014

This Online Privacy Notice (Notice) applies to the Rowley Wilson Auto Sales online interface (i.e., website or mobile application) and any Rowley Wilson Auto Sales affiliate or subsidiary online interface that links to this Notice, (each, a Site, and, collectively, Sites). The term "Rowley Wilson Auto Sales" or "we" or "us" or "our" in this Notice refers to affiliates or subsidiaries of Rowley Wilson Auto Sales that link to this Notice. This Notice describes how Sites may collect, use and share information from or about you and explains how information may be collected and used based on online interactions with our advertisements that appear on the Sites and third party websites.

Rowley Wilson Auto Sales may provide other online interfaces not covered by this Notice. If you visit or access one of these sites, please review the online privacy practices of that site to understand how your online information may be collected, used and shared.

For visitors to this Site, we will use and share any information that we collect from or about you in accordance with the Rowley Wilson Auto Sales Consumer Privacy Notice, which provides choices in the use and sharing of information.

Please note the terms and conditions of this Notice control. By using the Site, you agree to the terms and conditions of this Notice.

Personal Information means personally identifiable information such as information you provide via forms, surveys, applications or other online fields including name, postal or email addresses, telephone, fax or mobile numbers, or account numbers.

How We Use Personal Information

We may use Personal Information:

to respond to your inquiries and fulfill your requests;
to send you important information regarding the Site, changes to terms, conditions, and policies and/or other administrative information;
to send you marketing communications that we believe may be of interest to you;
to personalize your experience on the Site by presenting content, ads or offers tailored to you;
to allow you to apply for products or services (e.g., motor vehicle insurance, credit repair assistance, etc) and evaluate your eligibility for such products or services;
to verify your identity and/or location (or the identity or location of your representative or agent) in order to allow access to your accounts, conduct online transactions and to maintain measures aimed at preventing fraud and protecting the security of account and Personal Information;
to allow you to participate in surveys, contests or similar promotions and to administer these activities. Some of these activities have additional rules, which may contain additional information about how Personal Information is used and shared;
to allow you to use Site financial planning tools (e.g., car payment calculator); for business purposes, including data analysis, audits, developing and improving products and services, enhancing the Site, identifying usage trends and determining the effectiveness of promotional campaigns;
for risk control, for fraud detection and prevention, to comply with laws and regulations, and to comply with other legal process and law enforcement requirements.

How Personal Information is Shared

Please see the Rowley Wilson Auto Sales Consumer Privacy Notice at the top of this page for information on how Personal Information may be shared.

Other Information We Collect Online

Other Information is any information other than Personal Information that does not reveal your specific identity or does not directly relate to an individual, such as browser information, information collected through cookies, pixel tags and other technologies, demographic information, other information provided by you such as your date of birth or household income, and aggregated and de-identified data.

Consent for Electronic Documents under the Electronic Signatures in Global and National Commerce Act

I have read the Consent to Electronic Records below and agree to conduct transactions and receive records electronically.

To the extent permitted by law, the Finance Lending Institutions will provide all disclosures and notices to you in electronic form including, but not limited to, any notices (e.g., adverse action notice and privacy policy notice) required by the Equal Credit Opportunity Act, Gramm-Leach-Bliley Act, other federal law, and any implementing regulations. For purposes of this consent, these disclosures and notices are referred to as Records.

This Consent to Electronic Records informs you of your rights when Records will be provided to you electronically. By consenting, you acknowledge receipt of this Consent to Electronic Records and agree to the electronic delivery of the Records.

Hardware and Software Requirements. The Records will be provided to you either on the Finance Lending Institution’s website, in an email message, or as an attachment to an email message sent to the email address you provide as part of your request, application, or registration. To access the Records, you will need Adobe Acrobat Reader version 7 or higher, and a personal computer or other access device which is capable of accessing the Internet. To retain the Record, your access device must have the ability to either download the Records to your computer’s hard drive or print the Records.

Right to Withdraw Consent, Procedures for Withdrawal and Updating Information. You may withdraw your consent to receive the Records electronically at any time, or update your contact information at any time. You may withdraw consent or update information from CarFinance Capital LLC by emailing ElectronicRecords@CarFinance.com and withdrawing your consent or providing your updated contact information. You may withdraw consent or update information from Santander by calling 855-563-5635 and withdrawing your consent or providing your updated contact information.

Consent Applies to Transaction. Your Consent to Electronic Records applies to the transaction you've requested which may give rise to the obligation to provide the Records and to any other dealings or transactions you may have with Finance Lending Institutions.

Right to Paper Records and Copies of Records. You have the right to have the Records provided to you in paper form, rather than electronic form. If you wish to obtain the Records in paper form from Car Finance Capital, LLC contact CarFinance by emailing ElectronicRecords@CarFinance.com. If you wish to obtain Records in paper form from Santander contact Santander by calling 855-563-5635. A paper copy of the Record will be provided to you at no charge.

How We Collect and Use Other Information

We and our third-party service providers may collect and use Other Information in a variety of ways, including:

Through your browser: Certain information is collected by most browsers, such as your Internet Protocol (IP) address, device type, screen resolution, operating system version and internet browser type and version. We use this information to ensure Sites function properly and for security purposes.
Using cookies: Cookies are pieces of information stored directly on the device you are using. Cookies we use do not contain or capture unencrypted Personal Information. Cookies allow us to collect information such as browser type, time spent on the Site, pages visited, language preferences, and your relationship with us. We use the information for security purposes, to facilitate navigation, to display information more effectively, to personalize/customize your experience while visiting the Site, and to recognize your device to allow your use of our online products and services. We collect statistical information about the usage of the Site in order to continually improve the design and functionality, to monitor responses to our advertisements and content, to understand how visitors use the Site and to assist us with resolving questions regarding the Site. We also utilize cookies for our online advertising purposes. Please see the Advertising section below for more information. You can refuse to accept these cookies and most devices and browsers offer their own privacy settings for cookies. You will need to manage your cookie settings for each device and browser you use. However, if you do not accept these cookies, you may experience some inconvenience in your use of the Site and some online products and services. You also may not receive customized advertising or other offers from us that may be relevant to your interests and needs.
Using pixel tags, web beacons, clear GIFs or other technologies: These may be used in connection with some Site pages, mobile applications and HTML-formatted email messages to measure the effectiveness of our communications, the success of our marketing campaigns, compile statistics about usage and response rates, and to assist us in resolving questions regarding use of our Site.
IP Address: Your IP Address is a number that is automatically assigned to the device that you are using by your Internet Service Provider (ISP). An IP Address is identified and logged automatically in our server log files whenever a user visits the Site, along with the time of the visit and the page(s) that were visited. Collecting IP Addresses is standard practice on the internet and is done automatically by many web sites. We use IP Addresses for purposes such as calculating Site usage levels, helping diagnose server problems, for compliance and security purposes and administering the Site.
Aggregated and De-identified Data: Aggregated and De-identified Data is data that we may create or compile from various sources, including but not limited to user transactions. This information, which does not identify individual personal information, is used for our business purposes, which may include offering products or services, research, marketing or analyzing market trends, and other purposes consistent with applicable laws.

Additional Information

Lender Specific Information

Your Finance Application may be shared with the following consumer Finance Lending Institutions:

Other Finance Lending Institutions used to provide direct or indirect loans to consumers.

Receiving Electronic Documents

By submitting this application, I am providing my implied consent to recieve Commercial Electronic Messages (CEMs) as permitted within the provisions of the Canada Anti-Span Legislation (CASL) for the permitted durations under law.

That you can receive documents electronically and can access and retain those documents;
That you can receive and read email messages sent to the email address in your application;
That you can access information provided electronically at our website and other web sites related to your application;
To receive documents electronically and to store or print those documents for your records;
That the actions described here or on the documents will serve as your electronic signature on any such documents; and
That you are providing your consent to receive electronic communications from us under Canada's Anti-Spam Legislation (CASL), and intending that this law apply to your transactions with us.

If at any time in the future you change your mind and wish to remove yourself from receiving electronic messages from us, simply unsubscribe by clicking on the unsubscribe link at the bottom of our message.

Advertising

Rowley Wilson Auto Sales advertises on pages within the Sites (including mobile) as well as on other websites and mobile apps not affiliated with Rowley Wilson Auto Sales. Information collected by us or our advertising service providers through cookies and other technologies includes the number of people who look at each of the pages on the Sites, search engine referrals, browsing patterns within the Sites, and responses to advertisements and promotions on the Sites and on websites where we advertise.

We participate in cookie-based exchanges operated by BlueKai. They use cookies to collect anonymous information, which may be used to tailor the advertising you see elsewhere on the web, but we do not permit them to collect any personal information about you. Learn more about Blue Kai business practices and privacy policies, including how to decline participation in their program. You may also choose to opt-out from the eXelate program by visiting the opt-out page at the Network Advertising Initiative.

Advertising on our Sites

Rowley Wilson Auto Sales advertises our products and services on pages within the Sites. These advertisements may take the form of banner ads, splash ads, and other formats.

Relationship based advertising

Rowley Wilson Auto Sales may customize content and advertisements for our products and services on the Sites we own. In order to make the content and advertising as informative and useful as possible, we may use information about your relationship with us.

Online Behavioral Advertising

We may also use advertising service providers to help us determine which of our advertisements are most likely to be of interest to you using certain Other Information such as web pages visited, search keywords entered, or your activities on our Site. We limit access and collection of information for specific purposes by advertising service providers.

Rowley Wilson Auto Sales may contract with advertising companies to advertise our products and services on websites and mobile apps not affiliated with us. We may use Aggregated and De-identified Data and information provided by you to these third party websites to select which of our advertisements or offers may appeal to you, display them to you and monitor your responses. Third Party websites are not subject to Rowley Wilson Auto Sales Privacy Notices. Please visit the individual websites for additional information on their data and privacy practices and opt-out policies.

Some of our customized ads are behavioral advertising, and may be served using data collected through cookies and other technologies by third party websites. Cookies placed on our behalf by these companies, do not contain or capture Personal Information. We limit companies that place our ads from using information for any purpose other than to assist us in our advertising efforts.

Linking to other sites

We may provide links to third party websites, such as credit bureaus, service providers or merchants. If you follow links to websites not affiliated or controlled by Rowley Wilson Auto Sales, you should review their privacy and security policies and other terms and conditions, as they may be different from those of our Sites. Rowley Wilson Auto Sales does not guarantee and is not responsible for the privacy or security of these websites, including the accuracy, completeness, or reliability of their information.

Social media sites

Rowley Wilson Auto Sales provides experiences on social media platforms including, but not limited to, Facebook®, Twitter®, YouTube® and LinkedIn® that enable online sharing and collaboration among users who have registered to use them. Any content you post on official Rowley Wilson Auto Sales managed social media pages, such as pictures, information, opinions, or any Personal Information that you make available to other participants on these social platforms, is subject to the Terms of Use and Privacy Policies of those respective platforms. We may also utilize Google® Media Services and Google® Maps API(s) and by using such services from within our website you are equally subject and agree to Google’s Terms of Service and Google’s Privacy Policy. Please refer to them to better understand your rights and obligations with regard to such content. In addition, please note that when visiting any official Rowley Wilson Auto Sales social media pages, you are also subject to the Terms and Conditions of Rowley Wilson Auto Sales's Privacy Notices, Social Media User Terms and Community Guidelines

Security

To protect Personal Information from unauthorized access and use, we use security measures that comply with applicable federal and state laws. These measures may include device safeguards and secured files and buildings as well as oversight of our third party service providers to ensure information remains confidential and secure. Our websites utilize SSL Certificate encryption, the highest level of protection offered for Internet communications, to encrypt your information. Personally Identifiable Information is further encrypted within our database(s).

Protecting children’s privacy online

The Site is not directed to individuals under the age of thirteen (13), and we request that these individuals do not provide Personal Information through the Site. We do not knowingly collect information from children under 13. Visit the Federal Trade Commission website for more information about the Children's Online Privacy Protection Act (COPPA).

Updates to this Privacy Notice

This Online Privacy Notice is subject to change. Please review it periodically. If we make changes to the Online Privacy Notice, we will revise the “Last Updated” date at the top of this Notice. Any changes to this Notice will become effective when we post the revised Notice on the Site. Your use of the Site following these changes means that you accept the revised Notice.

Website Privacy Statement