PRIVACY POLICY

Last Updated: September 2016
© MINI Canada

MINI Canada, a division of BMW Canada Inc., our related companies, including MINI Financial Services Canada (“MINI Canada”, “we” or “us”) and service providers acting on our behalf collect, use and disclose personal information about you for the following purposes:

1. Delivery of Products and Services

• Processing applications for credit in respect of a lease or financing agreement;
• Registering you for and administering warranties, extended warranties and roadside assistance;
• Notifying you of service reminders, recalls and enhancements;
• Processing sales of accessories and merchandise;
• Administering billing for leasing or financing of vehicles or other products and services; and providing you with customer support services.

2. Customer Relations

• Promoting our vehicles, products and services;
• Administering promotional contests;
• Responding to requests for product and service information;
• Providing you with newsletters and other promotional news about upcoming events or special offers;
• Administering customer satisfaction surveys;
• Assessing the effectiveness of our marketing programs;
• Improving our products and services; and
• Developing a better understanding of your relationship with our retailers.

3. Protecting Our Business and Fulfilling Our Legal Obligations

• Collecting overdue payments from you and other debt collection matters;
• Repossessing our vehicles if you are in default;
• Securing our business and websites;
• Investigating and protecting against fraud, grey-marketing or other illegal activities; and
• To comply with legal and regulatory requirements, such as reporting obligations to the Financial Transactions and Reports Analysis Centre of Canada, complying with court orders, and responding to lawful police requests.

We and our service providers collect personal information for these purposes from you, MINI Retailers and, in some cases, third-parties. This information may be used by our service providers on our behalf and may be transmitted and stored outside of Canada.

If you have any questions about the collection, use and disclosure of your personal information that are not answered by this Privacy Policy, or you would like to access or correct your personal information, please contact our Privacy Officer by email at privacy@mini.ca; by telephone at 1-866-DRV-MINI; or by mail at 50 Ultimate Drive, Richmond Hill, ON L4S 0C8. All submissions should be directed to the attention of the Privacy Officer.

MINI Canada reserves the right to change this Privacy Policy from time to time and will provide notice of any significant changes on this website. Please check back frequently for updates.

What information does MINI collect and how is it used?

We collect personal information from you when you provide the information directly to us, such as when you contact us or when enter your personal information on our websites. Our websites include this website www.MINI.ca and other sites owned, operated, or controlled by MINI Canada and on which this Privacy Policy is posted (“our website(s)”).

Examples of information we collect and use are:

• Name, email address, password and vehicle identification number. We use this information to provide you with personalized MINI services.
• Your name, contact information, employment history, and information about your income, assets, liabilities, and credit history, if you apply for credit. We use this information to assess your application for credit.
• Your name, contact information, delivery information and payment information if you make a purchase so that we can process your transaction and deliver the goods or services to you.
• Your name and contact information if you participate in an online chat with one of our MINI representatives so that we can locate our discussion with you and follow-up with you if necessary.

We also collect your personal information from other sources, such as retailers, consumer reporting agencies, government agencies, and others. For example:

• We collect contact information and the type of vehicle that you have purchased from retailers in order to send you a welcome package.
• We collect information about you from retailers to administer your purchase of a MINI product and share repair or maintenance information about your vehicle when you seek service from another retailers.
• We collect credit information from consumer reporting agencies if you seek to finance or lease a vehicle from us.
• We may obtain information about you from government agencies in order to ensure that you have not violated your agreement regarding exporting a vehicle or in order for us to locate and repossess a leased or financed vehicle.

We and our third party service providers also collect information automatically using cookies, web beacons and other digital markers when you visit our websites. Please also see "What kind of information do you collect automatically on your websites?” below and our Cookies and Interest-based Advertising Disclosure for more information on how we use that information, and how you may opt-out of these practices.

We do not knowingly collect personal information from anyone under 13 years of age. If we become aware that we have unknowingly collected personal information from a child under the age of 13, we will delete this information from our records or, if that is not reasonable, we will take reasonable available steps to de-identify the information.

Do you share information with others?

Like other companies, we share information with our affiliated companies, third-party service providers, MINI retailer networks, and certain business partners (list available upon request) in order to conduct our business activities and to protect our rights. For example we share information with these other entities for the purposes of:

1. Delivery of Products and Services

• Delivering products and services to you on our behalf, including warranty services and roadside assist services.
• Arranging for a purchase or lease quote, or a test-drive.
• Assisting us with servicing and processing your credit account and verifying credit worthiness.

2. Customer Relations

• Administering our marketing promotions, including contests and email campaigns.
• Managing our interest-based advertising and website personalization programs.
• Evaluating the effectiveness of our products and services.

3. Protecting Our Business and Fulfilling Our Legal Obligations

• Detecting and preventing fraud.
• Enforcing contractual or other legal obligations.
• Locating and repossessing a leased or financed vehicle exported from Canada in violation of agreements.
• Responding to court orders, warrants and subpoenas or lawful requests for information by government institutions, including the police.
• Filing reports with government institutions where we are required by law to do so or we have grounds to suspect a breach of a law.
• Obtaining legal advice for MINI Canada, its affiliated companies or MINI Retailers.

We contractually require any third party organization to use and protect the personal information disclosed to them in a manner consistent with our Privacy Policy.

We may sell or purchase assets. If another entity acquires us or all or a portion of our assets, personal information that we collected from you may be shared with that entity. The information will be shared for the purpose of that entity considering whether to enter into the transaction and also to complete the transaction.

Our websites may include links to other websites outside of MINI Canada. We are not responsible for the content, links or privacy practices of those websites. We provide access to these linked sites for your convenience only and you access them at your own risk. However, we welcome any comments you may have regarding these linked websites to the contact information in “Who do I contact if I have questions or concerns about privacy at MINI?” below.

What kind of information do you collect automatically on your websites?

Like other companies, we automatically collect usage information when you visit our websites. Examples include your Internet Protocol (IP) address, browser and device type and operating system, and cookies information. We use this information for the purposes of:

• Recognizing you when you return to our website to make logging into our system easier.
• Delivering website pages in a format that is appropriate for your browser and device.
• Monitoring how our sites are being used and what information is being accessed. This provides us with information that assists us in improving our websites, products and services, and to detect and prevent security threats.

We use service providers to assist us. For example, we use third party service providers to assist us in personalizing our website for you. In addition, we use third-party analytics services that use cookies and other tracking technologies to help analyze how users use our websites. In some cases, information about your use of the website (including your IP address) will be transmitted to and stored by our providers on servers outside of Canada. These providers may also transfer this information to third parties where required to do so by law, or where such third parties process the information on their behalf.

For more information on our automatic collection of information on our websites, including how the information is used for advertising, or to disable cookies and/or opt-out of interest-based advertising, please see our Cookies and Interest-Based Advertising Disclosure.

Can I opt-out of receiving MINI marketing communications?

You may decide at any time that you would prefer not to receive marketing communications from MINI Canada.

If you wish to “unsubscribe” from our marketing communications, you may do so at any time online by accessing our Unsubscribe form or by contacting us at the contact information in “Who do I contact if I have questions or concerns about privacy at MINI?” below. Please allow up to 7 business days to process your request. Be assured that your decision to opt-out of our marketing communications will not affect your business relationship with us.

How long is my personal information retained?

MINI Canada will retain your personal information for as long as necessary to fulfill the purpose for which it was collected and to comply with applicable laws.

How do you protect my personal information?

At MINI Canada we are committed to protecting the personal information in our possession. We use administrative and technical controls, and require our service providers to take such measures, to help to maintain the security of your personal information. We have implemented security measures which include the use of: physical secure data centres and premises; internal security policies and procedures; defined internal segregation of duties; and electronic access controls such as passwords and encryption technology. However, please note that no system of protection can guarantee the protection of your personal information.

In addition, we encourage you to observe safe computing practices. It is your responsibility to keep confidential the user-ID and password that you use to register with us and not share them with anyone. If you believe that your user-ID and password have been compromised, contact MINI Canada at the contact information in “Who do I contact if I have questions or concerns about privacy at MINI?” below.

In certain parts of this website where we require that you provide us with sensitive personal information such as credit card information, we will protect the security of your personal information during transmission by using industry standard encryption technology. Please only submit this sensitive information within the secure area of the website where it may be specifically requested. Please do not send sensitive personal information via non-secure areas, including by email.

Where do you store my personal information?

We may use service providers who process or store information outside of Canada. In accordance with the laws of those countries, in certain circumstances your personal information may be accessible by foreign law enforcement, regulatory bodies or other authorities.

MINI Canada stores personal information in electronic format on servers located in the United States of America and maintained by various MINI entities in the United States. These MINI entities may be compelled to disclose this information to governmental agencies or security forces in the United States of America if required to do so by U.S. law.

How can I access my personal information?

At your request, we will let you know what personal information we have in our possession about you, what it is being used for, and to whom it has been disclosed. If you require access to your personal information please first check any account profiles that you have with us.

If you are unable to locate the personal information you require access to, please contact us at the contact information in “Who do I contact if I have questions or concerns about privacy at MINI?” below to request access. We will respond to your request within the time period prescribed by law. You may be requested to provide satisfactory identification and proof of entitlement to access your personal information. We will provide you with access to your personal information that is in our possession, subject to certain exceptions. For example, we may not provide you with your personal information where the information is subject to solicitor-client privilege or consists of references to other persons or proprietary information that cannot be severed from the record. There may be reasonable costs associated with your request.

How can I correct and update my personal information?

We strive to keep the personal information in our possession or control accurate, complete, current and relevant, based on the most recent information available to us. If you would like to correct the accuracy of any personal information we have about you, you may modify your information by contacting us at the contact information in “Who do I contact if I have questions or concerns about privacy at MINI?” below.

If you have provided information about yourself in order to receive emails or product mailings and would like to modify your information, please contact one of our Customer Service Representatives by calling 1-866-DRV-MINI or by mail to Customer Service, MINI Canada, 50 Ultimate Drive, Richmond Hill, ON L4S 0C8.

How do MINI Retailers manage my personal information?

MINI Retailers operate as separate and distinct legal entities from MINI Canada. Each retailer has its own privacy practices and policies and we are not responsible for their privacy practices or compliance with applicable privacy law. When communicating with a MINI Retailer, we encourage you to review their privacy policy and practices to understand how they collect, use and disclose your personal information.

How do third party applications collect my personal information?

Our websites may use third party social network plugins (“plug-ins”) from certain social networks.

When you visit a webpage that contains a plug-in, your browser establishes a direct connection with the servers of that third party social network. The content of the plug-in comes directly from the third party social network to your browser, which then integrates into our website. The plug-in provides the third party social network with the information that you have accessed the corresponding webpage of our website along with certain information, such as the date and time of access, and other browser-related information. If you are logged into the social network, the social network may also receive your user ID information and associate your activity with your account. If you interact with the plug-in, the corresponding information about your interaction or activity is transmitted from your browser directly to the third party social network and stored by it.

We do not control or collect the information collected by the plug-ins on our websites. Please carefully review the privacy practices of the third party social networks that provide the plug-ins to learn more about how they manage your personal information.

Who do I contact if I have questions or concerns about privacy at MINI?

MINI Canada has developed policies and procedures to respond to individual complaints and questions relating to privacy. We will investigate and attempt to resolve all complaints. We will respond to your inquiry within the time period prescribed by law. Please be advised that there may be a reasonable cost associated with your request.

If you have any questions or concerns about our privacy practices, please contact our Privacy Officer by email at privacy@mini.ca; by telephone at 1-866-DRV-MINI; or by mail at 50 Ultimate Drive, Richmond Hill, ON L4S 0C8.

We welcome your comments and emails but please note that any information, including but not limited to suggestions, ideas or submissions you make through and onto any MINI Canada website will become the exclusive property of MINI Canada.