Effective Date: January 1, 2019
1 - COMMITMENT TO PRIVACY
Fraserway RV Limited Partnership by its general partner, Fraserway RV GP Ltd., a British Columbia corporation and its affiliates (as identified under Section 18) (“Fraserway”, “we”, “our”, or “us”) are committed to maintaining the security and privacy of your personal information. This Policy documents our on-going commitment to you and has been developed in compliance with the British Columbia Personal Information Protection Act, SBC 2003, c 63 ("PIPA").
We are accountable and responsible for personal information under our control. For individuals in the European Union, we are the data controller of your personal data. We have designated a Privacy Officer who is accountable for our compliance with this Policy. If you have any questions about this Policy, please contact our Privacy Officer using the details set out under Section 19.
2 - SCOPE OF POLICY
This Policy informs you of our policies regarding the collection, use and disclosure of personal information (or personal data) about individuals outside Fraserway with whom we interact, including but not limited to visitors to our websites, clients, vendors, service providers and other contacts (collectively, “you”), and the rights you have associated with such information.
Personal information includes any information about an individual from which the person can be identified. Personal information does not include information where the identity of the individual has been removed (anonymous data), information concerning corporate or commercial entities or information that is publicly available.
3 - COLLECTION OF INFORMATION
We collect information including personal information as part of our business operation and in the provision of our products and services.
When you visit one of our websites, we automatically collect certain information about your device, including information about your web browser type, Internet Protocol (“IP”) address, device type, operating system, and cookies that are installed on your device (collectively, “Device Information”). As you browse the website, we collect information about the individual web pages or products or services that you view, what websites or search terms referred you to the website, and information about how you interact with our website (collectively, “Usage Information”).
We collect Device Information and Usage Information using cookies and other technologies. Please refer to the section entitled “Cookies Usage” for more information on the technologies that we use to collect Device Information and Usage Information.
We may also collect, use and store information about your location if you give us permission to do so. You can enable or disable location services when you use our websites at any time by way of your device settings.
Additionally when you sign up for an account, subscribe to our newsletters, submit an inquiry, share your information with us via social media, we collect certain information directly from you, including but not limited to your name, address, email address, phone number and payment information. If you wish to arrange financing through us, you may also provide to us your address, driver’s license number, year of birth, property ownership status, mortgage/rent payment, length at address, employment information and history, income, banking information, Social Insurance Number or Social Security Number (“SIN/SSN”), outstanding loan balances, and trade-in details. If you seek to finance or lease a RV from us, we may also collect your credit information from consumer reporting agencies.
We will not collect personal information indiscriminately and will limit the collection of your personal information to what is reasonably necessary to provide our products and services and which is reasonably necessary for the purposes consented to by you. We may also collect information as authorized by PIPA or other data protection laws and regulations (for example, the European Union General Data Protection Regulation or “GDPR”).
4 - PURPOSE
We collect your personal information for the following purposes:
- to provide and administer products and services requested and to use and disclose the information for any purpose related to the provision of requested products and services including billing you for the provision of requested products and services;
- to determine your potential needs and financial capabilities;
- to determine which products and services may meet your potential needs;
- to authenticate your identity;
- to communicate with you including but not limited to responding to your questions or concerns, sending notifications and emails to you about our products and services, soliciting feedback from you about our products and services, sending you administrative information such as updates to this Policy, and sending you news, special offers and general information about our other products, services and events that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information;
- to enable you to participate in interactive features of our websites when you choose to do so;
- to improve our websites, monitor the usage of our websites, detect, prevent and address technical issues related to our websites;
- to protect us, yourself and others from fraud and error and to safeguard our financial interests;
- to provide personal information to third party service providers who perform functions on our behalf;
- to collect debts owed to us;
- to manage or transfer our assets or liabilities, for example in the case of an acquisition or merger, the provision of security for a credit facility or the change of a carrier;
- to comply with legal and regulatory requirements;
- with respect to employees, to establish, manage and terminate employment relationship with you and to fulfill the purposes set out in our employment agreement with you.
The purposes listed above are a reasonably necessary part of your relationship with us.
When your personal information is to be used for a purpose not previously identified, the new purpose will be disclosed to you prior to such use, and your consent will be sought unless the use is authorized or required by PIPA or other data protection law and regulations.
5 - YOUR FEEDBACK AND COMMENTS
We may select and post customer testimonials, reviews and/or comments on our websites, which may contain information such as your name and/or the city, state or country in which you live. When submitting your testimonials, reviews or comments on our websites, you are giving us permission to post them on the websites and they will be available to other users of the websites. Your posting may also become public and we cannot prevent such information from being used in a manner that may violate this Policy or the law. If you would like us to remove your name, testimonial, review or comment from our websites, you may contact our Privacy Officer using the information provided in this Policy. Note that copies of information that you have updated, modified, or deleted may remain viewable in cached and archived pages of our websites for a period of time.
6 - COOKIES USAGE
Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. However, this may prevent you from taking full advantage of our websites. For more information about cookies and how to disable them, please visit http://www.allaboutcookies.org.
Our websites uses the following types of cookies:
- Necessary Cookies. These cookies are necessary for the proper function of a website, they enable basic functions like page navigation and access to secure areas of the website;
- Preference Cookies. These cookies enable a website to remember information that changes the way the website behaves or looks, like your preferred language or the region that you are in;
- Statistics Cookies. These cookies help us to understand how visitors interact with the websites by collecting and reporting information anonymously; and
- Social Media Buttons. Some of our websites include social media buttons to promote our social media channels such as our Twitter, Facebook, and YouTube channels. These buttons work through pieces of code that come from the social media service providers. Cookies are placed using these codes which we have no influence on. To understand how these social media service providers collect, use and otherwise process your personal information via these cookies, please review their privacy policies at:
- Facebook: https://www.facebook.com/policy.php
- YouTube: https://policies.google.com/privacy?hl=en
We also use Google Analytics to monitor and analyze the use of our websites. Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Such data are shared with other Google services. You can learn how to opt-out of Google Analytics by downloading the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics. For more information on Google’s privacy practices, please see Google Privacy & Terms at: https://policies.google.com/privacy?hl=en.
For more information on the privacy practices of Google and Facebook, please review Google’s Privacy & Terms at: https://policies.google.com/privacy?hl=en, and Facebook’s Data Privacy at https://www.facebook.com/privacy/explanation.
You can opt-out of remarketing by visiting the links below:
- Google AdWords: https://support.google.com/ads/answer/2662922?hl=en. You can also download the Google Analytics Opt-out Browser Add-on for your web browser at https://tools.google.com/dlpage/gaoptout; and
- Facebook: https://www.facebook.com/help/568137493302217.
Visitors from the European Union and United Kingdom may also set their cookie preferences here:
7 - DISCLOSURE
We will not use or disclose your personal information for purposes that are not identified at the time of collection, except with the consent of the customer or as otherwise required or permitted by law.
You may request a representative list of the third parties to which we disclose your personal information by contacting our Privacy Officer (see “INQUIRY AND QUESTIONS” section at the end).
We may share your personal information with the following third parties:
- third parties required to deliver a product or service to you, such as a delivery or postal service delivering a product that you have ordered;
- relevant credit reporting agencies, government institutions and insurance providers to process the purchase, lease, finance, or maintenance of a RV;
- third party promotions or loyalty programs, if you elect to participate;
- third parties who wish to send you information about their products and services, but only if you have given us consent to do so;
- law enforcement or government authorities where they have followed due legal process to request us to disclose the information;
- our advertising, marketing and promotional agencies to help us deliver and analyse the effectiveness of our advertising campaigns and promotions;
- third parties that provide services to us, such as web hosting, data analytics, payment processing, IT services, customer service and similar processing activities;
- our business partners to help develop and market programs, products or services and present targeted content including targeted advertising; and
- other third party businesses, if they are involved in the transaction you are engaged in (e.g., finance companies, leasing companies, registration services, title registration).
We may also share your personal information with the following companies, organizations or individuals outside of Fraserway if we believe that disclosure of such information is necessary for legal reasons:
- to conduct investigations into possible breaches of applicable laws;
- to detect, prevent and protect against fraud and any technical or security vulnerabilities; and
- to comply with applicable laws and regulations, co-operate in any legal investigation and meet enforceable governmental requests.
If we share your personal information with a third party, we will use our best efforts to ensure that they keep your information secure, take all reasonable steps to protect it from misuse and only use it in a manner consistent with this Policy and applicable data protection laws and regulations.
8 - CONSENT
We will seek your consent to collect, use or disclose personal information except where we are authorized or required by applicable data protection laws and regulations to do so without consent.
Your consent may be express or implied, or given through your authorized representative.
Consent may be provided orally, in writing, electronically, or otherwise. For example, oral consent could be expressed over the telephone at the time information is being collected; electronically when submitting an agreement, application or other information; or in writing when signing an agreement or application form.
You may withdraw your consent at any time, subject to legal or contractual restrictions, provided reasonable written notice of withdrawal of consent is given by you to us. Upon receipt of your written notice, we will inform you of the likely consequences of the withdrawal, which may include our inability to provide certain products or services for which the delivery of that information is a prerequisite.
9 - LEGAL BASIS FOR PROCESSING (FOR EU RESIDENTS ONLY)
For individuals in the European Union, our processing of personal data is justified on the following legal bases:
- Performance of Contract: the processing is necessary to perform a contract with you or take steps to enter into a contract at your request;
- Our Legitimate Interests: the processing is in our legitimate interests, namely, in using applicable information to conduct and develop our business activities, such as developing and maintaining relationships with our customers, to understand how our customers use our products and services, and to operate and grow our business (the majority of the processing covered by this Policy is legitimate interest based), subject to your interests and fundamental rights;
- Defend Our Rights: where the processing is necessary to the establishment, exercise or defence of legal claims; or
- With Your Consent: you have consented to the processing (for example, when you consented to receiving our newsletters, or when you completed our RV credit application and consented to us sharing your information with credit reporting agencies to investigate your credit and employment history).
10 - RETENTION OF INFORMATION
Your personal information will only be used or disclosed for the purposes set out above and as authorized by applicable data protection laws and regulations.
We will keep personal information for no longer than is necessary for the purposes for which the information was required, to comply with any of our legal obligations, to resolve disputes, or to enforce our contractual agreements.
Pursuant to the requirements of Section 35 of PIPA, we will keep personal information that was used to make a decision affecting an individual for at least one year.
Usage Data will be retained for internal analysis purposes, to strengthen security, and to improve the functionality of our websites. This information will be destroyed once it is no longer necessary for these purposes.
We will destroy, erase or make anonymous documents or other records containing personal information as soon as it is reasonable to assume that the original purpose is no longer being served by retention of the information and retention is no longer necessary for legal or business purposes.
We will take due care when destroying personal information so as to prevent unauthorized access to such information.
11 - SAFEGUARDING & THIRD-PARTY SITE
We protect the personal information under our control by making reasonable security arrangements to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks.
You should be aware that confidentiality and security are not assured when information is transmitted through e-mail or wireless communication. We will not be responsible for any loss or damage suffered as a result of a breach of security or confidentiality when information is transmitted by e-mail or wireless communication.
We will take all reasonable steps to ensure that personal information is handled securely and in accordance with this Policy.
12 - YOUR RIGHTS
You have the following rights regarding your personal information that is under our control:
- Right to Access
You may request access to your personal information held by us. Upon written request and authentication of identity, we will provide you with your personal information under our control, information about the ways in which that information is being used, sources that the information was collected from, and/or a description of the individuals and organization to whom such information has been disclosed.
We may charge a reasonable fee for providing the information in response to your request to cover our administrative costs and will provide an estimate of any such fee upon receiving your written access request.
We will make the information requested available within 30 days or provide written notice where additional time is required to fulfill the request.
In some situations, we may not be able to provide access to certain personal information. We may also be prevented by law from providing access to certain personal information.
Where an access request is refused in whole or in part, we will notify you in writing within 30 days of request, giving the reason for refusal and outlining further steps which are available to you.
- Right of Correction
We will comply with your request to correct incomplete or inaccurate parts of your personal information, although we may need to verify the accuracy of the new information you provide us. If appropriate, we will send the amended information to third parties to whom the information has been disclosed.
If you are a resident of the European Union, you will also have the following rights regarding your personal data under our control:
- Right to be Forgotten
Upon your request to erase your personal information under our control, we will do so promptly if the personal information is no longer necessary in relation to the purposes for which it was collected, you withdraw the consent which formed the basis of your personal information processing, you object to the processing of your personal information, the personal information was processed illegally, or if the personal information must be deleted for us to comply with our legal obligations.
When a request has been made and the personal information has been shared with third parties, we will take reasonable steps to inform third parties that process the information that you have requested it to be erased.
We may decline your request for deleting if the processing of your personal information is necessary to comply with our legal obligations, in pursuit of a legal action, or for the performance of a task in the public interest.
- Right to Stop Direct Marketing
At your request, we will stop using your personal information for the purpose of direct marketing. If you want to stop us from calling, emailing you in connection with marketing communications, please contact our Privacy Officer using the details set out at the end of this Policy.
Please note that even if we stop all marketing communications, you may still receive administrative communications from us.
- Right to Restrict Processing
At your request, we will limit the process of your personal information if the accuracy of the information is contested, the information was processed unlawfully but you oppose the erasure of your personal information, we no longer need your personal information but you require retention of the personal information in connection with a legal claim, or you object to the processing of your personal information pending verification of whether overriding legitimate ground for such processing exist.
We will make reasonable effort to inform third parties with whom your personal information has been shared of your request to restrict processing.
- Right to Data Portability
At your request, we will provide you free of charge with your personal information in our control in a structured, commonly used and machine readable format, if you provided us with the personal information, the processing of your personal information is based on your consent or required for the performance of a contract, or if the process is carried out by automated means.
13 - INTERNATIONAL TRANSFER
The websites, and the features and functionality of the websites, may be provided using resources and servers located outside the country in which you live or to other trusted third parties based in other countries so that they may perform functions on our behalf. Therefore, your personal information may be transferred, used, stored or otherwise processed outside the country where you access the websites. We will protect the privacy and security of personal information we collect in accordance with this Policy, regardless of where it is processed or stored. Such transfer is necessary for the purposes set out in this Policy. By allowing us to collect your personal information, you consent to such transfer and the processing thereof. While your personal information is located outside your home jurisdiction, it may be subject to the laws of the jurisdiction in which it is retained.
We contractually require agents, service providers, and affiliates who may process personal information related to the websites to provide the same level of protections for personal information as required under the Policy. We currently only transfer personal information to a third party for use in accordance with the purposes outlined in this Policy.
14 - CHILD PRIVACY
Our websites is not directed to, and we do not knowingly collect personal information from, persons under the age of majority. If you are under the age of majority in your home country, please do not use our websites. If we are made aware that we have collected any personal information from a minor without parental consent, and are asked to erase such information from our database, we will do so without undue delay.
15 - AUTOMATED DECISION MAKING
Automated decision making takes place when our electronic systems process your personal information to make a decision about you without human intervention.
You will not be subject to decisions that will have a legal or significant impact on you based solely on automated processing, unless we have a lawful basis for doing so and we have notified you.
16 - DO NOT TRACK
We do not support Do Not Track (“DNT”). DNT is a preference you can set in your web browser to inform websites that you do not want to be tracked.
You can enable or disable DNT by visiting the Preferences or Settings page of your web browser.
17 - CHANGES TO POLICY
To keep pace with economic and technological changes, we may revise this Policy from time to time. We will inform you of any material changes via a prominent notice on our websites prior to the change coming into effect. The “Effective Date” at the top of this Policy will be updated with each amendment. We advise you to review this Policy from time to time for any changes.
18 - FRASERWAY AFFILIATES
- Travelhome the RV Marketplace a Division of Fraserway RV, a British Columbia sole proprietorship
- Country RV, a Division of Fraserway RV, a British Columbia sole proprietorship
- Adventurer MFG Limited Partnership, a British Columbia limited partnership
- Four Seasons RV Rentals a Division of Fraserway RV, a British Columbia sole proprietorship
- Specialty RV Products, a Division of Fraserway RV, a British Columbia sole proprietorship
- Adventurer LP, a Washington limited partnership
- Adventurer GP Ltd, a Washington corporation
19 - INQUIRY AND QUESTIONS
If you are a resident of the European Union, you are entitled to make a complaint to the Data Protection Authority in the Member State in which you habitually reside. However, we would appreciate the chance to deal with your concerns before you approach the Authority so please contact us in the first instance.
Fraserway RV Limited Partnership by its general partner, Fraserway RV GP Ltd.
30440 S Fraser Way,
Abbotsford, BC V2T 6L4