Affinity Auto Group Inc. is committed to protecting the privacy of its Clients. We have created our Privacy Policy to ensure that all of our Clients are protected to the best of our ability. This policy was developed in compliance with the British Columbia Personal Information Protection Act.

Definitions

"Affinity Auto" / "We" - refers to Affinity Auto Group Inc., its subsidiaries and affiliated companies.

"Client" / "You" - is any individual or corporation who uses or proposes to use the services of Affinity Auto.

"Collection" - is the act of gathering, acquiring, and obtaining Personal information from any source, including third parties, by any means.

"Consent" - involves voluntary agreement with what is being done or proposed. Consent may be expressed or implied. Express consent can be given orally or in writing, it is unequivocal, and does not require any inference on the part of Affinity Auto. Implied consent exists when Affinity Auto can reasonably infer consent based upon the action or inaction of the Client.

"Disclosure" - is the act of making Personal information available to others outside of Affinity.

"Personal Information" - is information about an identifiable individual that is recorded in any form; excluding the individual's name, business title, business address and business phone number.

"Privacy Officer" - is an individual designated by the Board of Directors of Affinity Auto to be accountable for Affinity Auto’s compliance with this Policy and who can be contacted as set out at the end of this Policy.

"Third Party" - is any individual or organization other than Affinity Auto / the Privacy Officer and the Client.

"Use" - is the treatment and handling of Personal Information by and within Affinity Auto.

Section 1: Accountability

1.0 Affinity Auto is responsible and accountable for Personal information under its control. All employees are required to adhere to the Privacy Policy and Affinity Auto has assigned a Privacy Officer to ensure compliance with this policy.

1.1 Affinity Auto is committed to ensuring that all appropriate security measures are in effect to protect Personal Information.

1.2 Affinity Auto will not be accountable for any damages suffered when a Client transmits Personal Information through its online Website application or via email.

1.3 Affinity Auto has developed these policies and procedures to protect Personal and corporate information; receive and respond to complaints and inquiries; and to communicate the policies and procedures to our Clients.

Section 2: Identifying the Purposes of Personal Information

2.0 Affinity Auto will state the purposes for which information is collected. This information is available from the Privacy Officer, who can be contacted at the address indicated at the bottom of this document.

2.1 Affinity Auto collects Personal information for the following reasons:

• to sell products and to provide financial services, leases and loans;
• to determine Clients’ financial situations including the obtaining of credit reports;
• to establish and maintain a responsible commercial relationship with Clients and to provide ongoing service;
• to develop and manage products and services to meet the needs of Clients;
• to contact Clients directly for products and services that may be of interest;
• to ensure a high standard of service; and,
• to meet legal and regulatory requirements.

Section 3: Consent

3.0 Affinity Auto will obtain Client consent to collect, use or disclose any Personal Information, except where detailed in the Privacy Policy.

3.1 A Client's consent can be expressed, implied, or given through an authorized representative such as a lawyer, agent or broker. Consent can be withdrawn anytime, with specific exemptions (see section 3.3). Affinity Auto, however, may collect, use or disclose Personal Information without the Client’s knowledge or consent in exceptional circumstances, including but not limited to situation where:

• it is permitted or required by law;
• we are acting in an emergency;
• the life, health, or personal security of any person is threatened;
• the information is publicly available; and,
• we require advice from a lawyer or professional advisor.

3.2 Expressed consent may be given orally, in writing, or electronically.

3.3 Subject to contractual or legal arrangements, Clients may withdraw or refuse consent provided that Affinity Auto is given reasonable notice (30 days is requested). Refusal or withdrawal of consent may prevent Affinity Auto from providing a product or service to the Client as in the case where a Client is applying for credit and will not provide relevant credit information. Affinity Auto will not unreasonably withhold products or services from Clients who refuse or withdraw consent, but if information is required by law, or would reasonably be required to conduct business, Affinity Auto may decline to deal with a Client who will not consent to the use of such information.

Section 4: Limits for Collecting Personal Information

4.0 Affinity Auto will only collect Personal Information for the purposes identified. Affinity Auto will use methods that are lawful and will not collect information indiscriminately.

Section 5: Limits for Using, Disclosing, and Keeping Personal Information

5.0 Client information will only be used or disclosed for the purpose for which it was collected.

5.1 Affinity Auto will never sell Client lists or Personal Information to Third Parties.

5.2 Affinity Auto may periodically use Personal Information to conduct surveys in order to enhance the provision of services.

5.3 Affinity Auto will retain Personal Information only as long as necessary or expected to be necessary for the identified purposes or as required by legislation.

Section 6: Accuracy

6.0 Affinity Auto will make reasonable efforts to ensure that Personal Information is as accurate, complete, and current as required for the purposes for which it was collected. In some cases, Affinity Auto relies on its Clients to ensure that certain information, such as Clients’ contact information, is current, complete, and accurate.

Section 7: Safeguarding Personal Information

7.0 Affinity Auto is committed to the safekeeping of Personal Information in order to prevent its loss, theft, unauthorized access, disclosure, duplication, use, or modification. Affinity Auto will employ all appropriate security measures to protect Personal Information and has invested substantially in security measures to protect the physical locations, electronic servers, Website(s), and email systems where Personal Information is stored or transmitted. While every effort is made by Affinity Auto to safeguard electronic communications, complete confidentiality and security of Internet-based communications cannot be guaranteed due to the unavoidable vulnerability of these media.

7.1 When disposing of Personal Information, Affinity Auto will exercise every reasonable effort to irreversibly destroy the data to prevent unauthorized Third Parties from accessing it.

Section 8: Availability of Policies and Procedures

8.0 Information about Affinity Auto's policies and procedures will be made available to Clients upon request, either electronically or in written format. However, to ensure the integrity of our security procedures and business methods, Affinity Auto reserves the right to refuse to disclose certain information.

8.1 Affinity Auto will make the following information available:

• The name, title and address of the person accountable for the policies and procedures and to whom complaints or inquiries can be forwarded;
• A description of the type of Personal Information held by Affinity Auto, including a general account of its use;
• A copy of any brochures or other information that explain the policies and procedures; and
• An explanation of what Personal Information is made available to related organizations such as affiliated companies.

Section 9: Providing Client Access to Personal Information

9.0 Upon request, Affinity Auto will provide a Client with certain details about the Personal Information that it holds about them, what the Personal Information has been or is being used for, and to whom it has been disclosed, if applicable. The information will be made available in an appropriate format for Clients with a sensory disability.

9.1 Clients will be asked to be specific about the Personal Information that they would like to obtain information about. Any requests must be submitted in writing to Affinity Auto's address as set out at the end of this Policy.

9.2 Clients will be required to provide information and documents to identify themselves to enable Affinity Auto to provide an account of the existence, use, and disclosure of Personal Information.

9.3 Affinity Auto will make every reasonable effort to make the requested information available within 30 days, or provide written notice of extension where additional time is required to fulfill the request.

9.4 The information will be made available at a cost that will vary with the type and amount of information requested. Where a cost will be incurred by the Client, Affinity Auto will inform the Client of the cost and request further direction from the Client on whether or not Affinity Auto should proceed with the request.

9.5 If a request for information is refused, Affinity Auto will notify the Client in writing, documenting the reasons for refusal and resources for redress available to the Client.

9.6 Affinity Auto reserves the right, at its sole discretion, to refuse to disclose certain information that may be contained in the Personal Information about a Client.

9.7 In certain situations, Affinity Auto may not be able to provide access to any or all Personal Information about a client. In such cases, Affinity Auto will explain the reasons it will not provide the requested information, and identify resources for recourse available to the client. Affinity Auto may not be able to provide information to a client if:

• The information would be unreasonably costly to provide;
• The information would threaten the life or security of any person;
• The information is generated in a formal dispute resolution process;
• The information contains references to or information about other individuals;
• The information cannot be disclosed for legal, security, or commercial proprietary reasons;
• The information is subject to solicitor-Client or litigation privilege.

9.8 If any information is demonstrated to be inaccurate or incomplete, Affinity Auto will amend the information as required. Where appropriate, Affinity Auto will transmit the amended information to Third Parties having access to the information in question.

Section 10: Compliance and Complaints

10.0 Clients are asked to direct any complaints, concerns or questions regarding this privacy code in writing to the Privacy Officer. If the Privacy Officer is unable to address the Client's concerns, the issue can be referred to the office of the President. At any point in this process, the Client may also write to the Privacy Commissioner.

10.1 Contact information (Please direct correspondence to the Attention of the Privacy Officer):

Affinity Auto Group Inc.
1918 Fir Street
Vancouver, BC
Canada V6J 5E2

Telephone: (604) 730-1001
Facsimile: (604) 730-8010