Last Update: September 2023
GENERAL MOTORS FINANCIAL OF CANADA, LTD.
Table of Contents:
Personal Information We Collect
How We Use Your Personal Information
Retention of Personal Information
Disclosing Personal Information To Third Parties
Third Party Collection of Personal Information
Do Not Track
The Accuracy Of Your Personal Information
Access To and Correction of Personal Information
Protecting Your Personal Information
Changes To This Statement
General Motors Financial of Canada, Ltd. and its subsidiary GM Financial Canada Leasing Ltd. (collectively, “GM Financial”, “we”, “us” and “our”) are committed to respecting and protecting customer privacy. This Privacy Statement explains what information GM Financial may collect about you when you use the GM Financial website, https://www.gmfinancial.ca (“Site”), or GM Financial products or services (“Services”), and how we use, protect, transfer, disclose and retain that information. Personal information (“Personal Information”) is information (including sensitive personal information) about an identifiable individual, as more particularly described by applicable privacy legislation.
Please read this Privacy Statement carefully. By using the Site or the Services, you consent to the collection and use of your Personal Information as described in the Privacy Statement. If you do not agree with the terms of the Privacy Statement, please do not use the Site or Services. Our Site may provide links to other websites which are not governed by our Privacy Statement. We encourage you to read the privacy statement of every website you visit.
PERSONAL INFORMATION WE COLLECT
GM Financial may collect Personal Information as necessary to deliver financial products and services to you. The Personal Information we may collect includes:
· Information you provide to us when you register on MyAccount, including your first and last names, GM Financial account number, email address, and vehicle information such as make, model, and vehicle identification number ("VIN");
· Information you provide when completing a GM Financial credit application either verbally or in writing, including but not limited to, your first, middle and last names, physical address, length of time at current address, home, business and cellular telephone numbers, e-mail address, date of birth, social insurance number (if provided), employment status, job title, employer name, employer phone number, length of time at place of employment, income information, tenancy arrangements (including whether you own a house or rent, monthly mortgage or rental payment amounts, total mortgage amount, mortgage holder, market value of home, total monthly recurring disbursements related to housing), and insurance, banking or credit institutions you use or have used, and personal references;
· Other information you may provide on applications, conditional sales contracts, lease agreements, and other forms including length of time at current address, marital status, gender, driver’s licence information, social insurance number (if provided), date of birth and information about the vehicle(s) you are leasing, financing, or purchasing;
· Banking information including the name and contact information for your bank and your account number, in order to process pre-authorized payments;
· Information from commercially available third party sources, such as consumer reporting agencies and identity verification services, which may be combined with the information you provide when completing a GM Financial credit application;
· Information about the device or computer you use to access the Site, including device ID, device and platform type, operating system, IP address, browser type and version, domain name, and referring website/service/application;
· Information that you send directly to GM Financial or post to any of GM Financial’s social media websites for publication on the Internet, such as your first and last names, user name, profile picture, user preferences such as “Like” button clicks, and the content of your posts;
· Information about or to assist with transactions you might conduct through us that involve a third party optional service/product provider;
· Information about transactions we conduct for or with you and services we provide or may provide to you;
· Information about your transactions with third parties such as the dealer from which you seek to buy or lease a vehicle for which you need financing;
· Information that may assist in expanding our business relationship, such as information related to your preferences, service needs and decision-making or about customer service inquiries and feedback; and
· Other information with your consent or as permitted or required by law.
We generally obtain Personal Information directly from you. However, with your consent, we may also obtain information about you from other sources such as the dealer from whom you seek to buy or lease a vehicle for which you need financing, credit reporting agencies, collection agencies, financial institutions, your past and present employers and creditors, your co-applicant, insurers, and other third parties relevant to the purposes described below.
You are not required to provide us with your social insurance number. However, if provided, we will use it to ensure that there is a match with your credit bureau information and to verify the accuracy and completeness of the information we obtain.
HOW WE USE YOUR PERSONAL INFORMATION
GM Financial uses your Personal Information to manage and administer our business including:
· To process your GM Financial credit application, evaluate your eligibility for financial products and services, and fulfill our contractual obligations to you;
· To obtain credit reports from consumer credit reporting and collection agencies, financial institutions or finance companies;
· To manage, administer, collect and enforce accounts, collect debts owed to us and process payments;
· To communicate with you about the Site or Services, such as to send you account updates or other communications regarding your account or to inform you of any changes to the Site or Services;
· To send you information about promotions or other marketing material;
· For specific purposes for which you provide consent;
· To provide you support or other services you request, for example technical support or to answer questions about the Site or Services;
· To maintain and improve the Site and Services and improve user experience;
· To meet our legal, regulatory insurance, security and processing requirements;
· To investigate and adjudicate any dispute or claim which relates to the Services that we offer to you, including to defend and bring legal actions;
· To maintain records for reasonable periods;
· In connection with certain business transactions involving our assets or business as further described in the “Disclosing Personal Information To Third Parties” and “Third Party Collection of Personal Information” sections below;
· For any other purpose to which you consent or which is permitted or required by law; and
· For any other legitimate business purpose.
Unless you opt-out, GM Financial may use your Personal Information for promoting products and services to you and may contact you from time to time to advise you of special offers or customer programs that we may offer and that you may qualify for. In order to do so, GM Financial may use your Personal Information to determine if you qualify for such offers or customer programs and to contact you using the contact details you have provided. If you do not wish to be contacted by GM Financial for offers or customer programs, please let us know by contacting us by e-mail, by calling us or by writing to us at the contact information provided below.
RETENTION OF PERSONAL INFORMATION
We will retain your Personal Information for as long as needed to deliver financial products and services to you, to manage and administer our business as outlined above, or as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
DISCLOSING PERSONAL INFORMATION TO THIRD PARTIES
Personal Information may be transferred to or collected by the following third parties or outside agents or service providers (including our affiliates acting in this capacity) that perform services on our behalf for the purposes specified:
· Service Providers. We may use third parties to provide you with products and services you request. If you are a customer, we may disclose the information we collect about you as described herein and in accordance with applicable law.
· Affiliates. For customers, we may share Personal Information within the General Motors family of companies for analytical purposes, user preferences, and as described herein, in accordance with applicable law.
· Dealers. We may share your credit application information with the dealer you select during the credit application process, in accordance with the terms and conditions of that process and applicable law, for the purposes of servicing your account and for our record keeping purposes.
· Change in Corporate Structure. We may share information in connection with a merger, acquisition, consolidation, change of control, or sale of all or a portion of our assets or if we undergo bankruptcy or liquidation.
· Credit Bureaus and Consumer Reporting Agencies. We may report the status of your account with us to credit bureaus, credit reporting agencies and to your current or future creditors for the purpose of maintaining your credit history and providing credit references.
· Financial Institutions. We may share Personal Information with financial institutions for payment processing purposes.
· Enforcement of Agreements and Collection or Payment of Debts. We may share Personal Information with third parties as reasonably necessary to enforce your agreements with us and otherwise for the collection or payment of a debt owed to us or our affiliates.
· Fraud Prevention. We may share Personal Information for the purposes of detecting and preventing fraud.
· The Ministry of Transportation. We may share Personal Information with the Ministry of Transportation offices or other licensing services as required for licensing and registration of the vehicle(s) that you have leased, financed, purchased, or traded-in.
· Other Disclosures. We may also disclose your Personal Information for audit purposes; for the purposes of meeting legal, regulatory, industry self-regulatory, risk management and security requirements; when we believe that disclosure is necessary to protect our rights or to comply with a judicial proceeding, court order, or legal process; or for any other purpose to which you consent or that is permitted or required by law.
Personal Information may also be disclosed to the automotive manufacturer of the vehicle forming the subject matter of the financing or lease agreement ("Manufacturer") and the Manufacturer's authorized dealers, in order that they may meet safety, security, legal and regulatory requirements, including with respect to potential recalls; maintain accurate records to respond to inquiries, provide warranty or other customer service communications and otherwise better understand and manage their relationship with you; conduct research and analytics and to satisfy other reasonable, legitimate business interests. Unless you opt-out, Personal Information may also be disclosed by GM Financial to Manufacturers, their authorized dealers and their affiliates to provide you with general marketing, product, service and business partner information and offers, including end of financing or lease offers and re-marketing of lease terms, as well as customizing and improving communication content and online advertising to you and others (which may include targeted ads on social media and other websites).
Personal Information may be disclosed to our affiliates (including outside of Canada) for internal audit, management, billing or administrative purposes, including defending and bringing legal actions. Unless you opt-out, Personal Information may also be disclosed to our affiliates so that they may provide you with special offers that may be of interest to you.
Personal Information may be used by GM Financial and disclosed to parties connected with the proposed or actual financing, securitization, insuring, sale, assignment or other disposal of all or part of GM Financial or our business or assets (including your lease or loan agreement), for the purposes of evaluating and/or performing the proposed transaction. Assignees or successors of GM Financial or our business or assets may use and disclose your Personal Information for similar purposes as those described in this Privacy Statement. Some of these third parties may be located outside of Canada, including in the United States. As a result, your Personal Information may be collected, processed and stored in another jurisdiction. Reasonable contractual or other measures we may take to protect your Personal Information while processed or handled by these service providers are subject to legal requirements applicable to our service providers, such as lawful requirements to disclose Personal Information to government authorities in certain circumstances.
If you do not wish to be contacted by third parties for promotional and marketing purposes, please let us know by contacting us by e-mail, by calling us or by writing to us at the contact information provided below.
THIRD PARTY COLLECTION OF PERSONAL INFORMATION
GM Financial may place or allow third party service providers to place persistent identifiers such as cookies, pixel tags, and web beacons on the Site.
Cookies, pixel tags, and web beacons are used for the following purposes:
· Beacons to store preferences you demonstrate on the Site. For instance, we may store your User ID so that you do not need to reenter it every time you visit MyAccount.
The information that GM Financial or third parties may collect with persistent identifiers includes the date and time of your visit to the Site, your computer's IP address and the pages of our website that you visited.
We use third-party tools (such as Adobe and Google Analytics and other Google services), to support the operation and performance of our online properties and to analyze interactions and experiences with our properties, including the features you engage with, how you navigate, and your click/touch, movement, scroll, and keystroke activity.
The information they collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services.
Do Not Track. Certain web browsers may provide an option by which you can have the browser inform websites, or Internet services you visit that you do not wish to have your activities tracked by cookies or other persistent identifiers across time and across third party Internet websites, online or cloud computing services, online applications, or mobile applications. These are commonly called "Do Not Track" signals. At this time, the Site does not honor Do Not Track signals from web browsers because it may diminish the optimal performance of the Site. However, you may refuse or delete cookies. Please refer to your browser’s Help instructions to learn more about cookies and other technologies, and how to manage their use. If you do elect to refuse or delete cookies, you will need to repeat this process if you use another computer or change browsers. If you choose to decline cookies, some of the functionalities of websites may be impaired.
GM Financial processes Global Privacy Control preference signals. GM Financial applies the Global Privacy Control signal at the browser level.
GM Financial generally collects, uses, transfers and discloses your Personal Information with your consent, except as permitted or required by law. Depending on the sensitivity of the Personal Information, your consent may be implied or express. Express consent can be given orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from your action or inaction. You may provide your consent in some circumstances where notice has been provided to you about our intentions with respect to your Personal Information and you have not withdrawn your consent for an identified purpose, such as by using an opt-out mechanism provided, if any. Generally, by providing us with Personal Information, we will assume that you consent to our collection, use and disclosure of such information for the purposes described in this statement or otherwise at the time of collection.
You can refuse to consent to our collection, use, transfer or disclosure of your Personal Information, however, we may then not be able to provide you with the products or services you request. Subject to legal and contractual restrictions, you may withdraw your consent to our further collection, use or disclosure of information at any time by giving us reasonable notice. However, you may not be permitted to withdraw your consent to certain necessary collections, uses and disclosures of your Personal Information (for example but not limited to maintaining reasonable business and transaction records and the ongoing disclosure of your Personal Information to consumer credit reporting agencies) and if you withdraw your consent to certain collections, uses and disclosures of your Personal Information we may no longer be able to provide you with financial products or services.
THE ACCURACY OF YOUR PERSONAL INFORMATION
GM Financial strives to ensure that the information we hold about you is as accurate, complete and up-to-date, as is necessary for the purposes for which it is to be used. To be able to do so, GM Financial requires notification of any changes to your Personal Information such as your name, address or other relevant information. GM Financial regularly updates your credit bureau to provide accurate and up to date reporting relative to the financial services provided to you.
ACCESS TO AND CORRECTION OF PERSONAL INFORMATION
The GM Financial entity with whom you are dealing may establish and maintain a file of your Personal Information for the purposes described in this Privacy Statement, which will be accessible at the applicable GM Financial office as set out below. If you wish to request access to or correction of your Personal Information in our custody or control, you may make changes to the information that you provide to us on the MyAccount Site by logging into MyAccount and selecting “My Profile.” You may also select the “Contact Us” tab on the Site to ask us any questions, or write to the applicable GM Financial office at the address provided below, attention Privacy Officer. Your right to access or correct your Personal Information is subject to applicable legal restrictions. We may take reasonable steps to verify your identity before granting access or making corrections.
PROTECTING YOUR PERSONAL INFORMATION
Protecting your Personal Information is important to us. Therefore, access to your information is limited to our employees, mandataries, agents and service providers who need access in order to perform their job or provide services to us. We take reasonable steps to protect your Personal Information, using physical, procedural, and electronic security measures that are appropriate to the sensitivity of the information, which may include safeguards to protect against loss or theft, as well as unauthorized access, disclosure, copying, use or modification. We maintain reasonable physical, electronic, and procedural safeguards designed to protect against loss or unauthorized access, disclosure, alteration, or destruction of the information you provide on the Site. However, no method of transmission over the internet or electronic storage technology is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security. The security of your information also depends on the security of the electronic devices and internet service provider network that you use to access the Site. We are not responsible for the security of your information accessed on those devices or networks.
The Site is not intended for use by children under the age of majority, and we do not knowingly collect Personal Information from children under the age of majority. Please contact us if you believe we may have unknowingly collected information about a child under the age of majority, and we will take immediate steps to delete any such Personal Information.
If you have any questions or concerns regarding our privacy practices, or would like to opt-out of the use and disclosure of your Personal Information for marketing purposes (as described above), you may contact us by the following means:
By Mail: 2001 Sheppard Avenue East, Suite 600, Toronto, ON, M2J 4Z8
By Telephone: Toll Free: 1-877-346-5469
By Email: firstname.lastname@example.org
Attention: VP Credit and Risk Management, Privacy Officer
For Privacy requests, please download and complete GM Financial’s Privacy Request Form and email to email@example.com or return via mail at the address noted above.
CHANGES TO THIS STATEMENT
This Privacy Statement may be revised from time to time. If we intend to use or disclose Personal Information for purposes materially different than those described in this statement, we will make reasonable efforts to notify affected individuals, if necessary, including by revising this Privacy Statement. If you are concerned about how your Personal Information is used, you should contact us as described above to obtain a current copy of this statement. Your continued provision of Personal Information or use of our services following any changes to this Privacy Statement constitutes your acceptance of any such changes. You may determine when this Privacy Statement was last updated by referring to the date found on the first page.