Effective Date: December 16, 2019
Scope of This Policy
This Policy includes the following sections. You should read the entire Policy; however, you may use the links below to be directed to the information you want:
- What is Personal Information?
- What Personal Information We Collect, and Where We Collect It
- How We Use Your Information
- How We Share Your Information
- Your Rights and Choices Regarding Your Personal Information
- How We Protect Your Information
- We may Transfer Personal Information to Other Countries
- These Sites Are Not Intended for Children
- Links to Other Websites
- Correcting Your Information
- Additional Privacy Notices
- This Policy May Change
- Questions About This Policy or Triple E’s Data Practices
By using this Site, or by providing us with personal information, you consent to the collection, use, disclosure, and transfer of your information as described in this Policy (and any Privacy Notices that apply to you).
If you do not consent to the collection, use, disclosure and transfer of your information as described in this Policy (and any Privacy Notices that apply to you), do not use this Site, or provide us with personal information.
If you have questions about this Policy, or any Privacy Notice, please contact us at [email protected].
2. What is Personal Information?
We collect information about or related to you through this Site. Some of the information we collect is “personal information”—information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked to you or your household, either alone or when combined with other information we have.
3. What Personal Information We Collect, and Where We Collect It
We collect and receive the following categories of personal information from and about you:
- Triple E collects your name, your phone number, email address, mailing address, biographical information, user name, profile photo, Profile Information (as defined below), User-Generated Content (as defined below), your IP address, and information about your vehicle (including the year, make, and model). We may also collect your social media user names, handles, and information from your profile on that social media platform. We call this category of personal information “Identifiers” in this Policy.
- How and where we collect Identifiers: We collect this information directly from you and your devices. We collect this information when you choose to provide it to us when you use this Site, or use other means to provide us with information (for example, when you contact us by email, telephone, or using a ‘live chat’ feature on our Site). For example, we may collect it when you complete a profile or communicate with us through the Site. We may also collect this information when you register with, log on to, or use this Site and choose to automatically complete forms with your information from a social media platform (such as Facebook or Twitter). We may also collect this information through other features on the Site that interact with social media platforms, such as tools allowing you to share content to social media, or to “like” content on our Site. We may collect this information if you post it to public spaces on our Site. We also receive this information from vendors who collect it on our behalf. We may combine Identifiers that we have collected offline with information we collect online. Or we may combine Identifiers we get from a third party with information we already have.
- Internet and Network Activity. We collect information that is sent to us automatically by your web browser or mobile device. This information includes the name of your operating system, the name and version of your browser, the date and time of your visit to our Site, and the pages you visit on our Site.We also use “cookies” and other tracking tools to collect information and support certain features of this Site. A cookie is a small file assigned to your Internet browser that can collect and store information. These include temporary cookies or similar technologies that remain on your device until you close your browser, or, in some instances, cookies or similar technologies that stay on your device for a longer period of time. We may use both first party and third party cookies, as well as pixels and other technologies, to track activities you take on our Site. We collect information about users over time and across different websites when you use this Site. The information we collect using these tools includes: (i) information about the browser you use, page location, the site you reach us from, and any other information in the HTTP header; (ii) information about your visit to our Site, such as the time of your visit, the buttons you click on our Site, the pages you visit on our Site, what fields you complete on our Site and the identity of the website you visited immediately before coming to our Site; and (iii) how you interact with communications we send you, such as whether you open an email we send you. We call all of this information “Internet and Network Activity.”
- How and where we collect Internet and Network Activity: We may collect this information directly. We may have third parties collect information this way. These third parties may include online analytics partners, such as Google Analytics and Intercom. These third parties may also include social media platforms, such as Facebook and Twitter. The information we receive may depend on your browser or device settings. Your privacy settings on a particular social media platform may also affect the information we receive.
- Location Information. If you expressly consent, we may use GPS technology to collect precise, real-time location information from your mobile device and use that information to deliver tailored content through this Site.
- How and where we collect Location Information: We may collect precise, real-time location information from your mobile device, if you expressly consent. We may also collect your general geographic location if you choose to share it.
- Employment-Related Information. We may collect information about your work experience and previous employment, your education history, your resume, the URL to your personal or professional websites, your workplace skill sets and certifications, whether you need a visa, and salary expectations. If you apply for a job, you can choose to also voluntarily provide any of the following information: ethnicity, gender, disability status, and/or veteran status.
4. How We Use Your Information
We use certain categories of personal information for the business purposes described below:
- We use information to provide our products and services. We use Identifiers, Payment Information, Purchase Information, Internet and Network Activity, and Location Information to provide the information, products and services you request, including to process payment and to deliver products and services.
- We use information to improve our products and services. We use Identifiers, Purchase Information, Internet and Network Activity, and Location Information to customize your experience with us and provide you with a personalized experience when you use this Site. We may use Identifiers, Purchase Information, Internet and Network Activity, and Location Information to help us improve our products and services, and improve this Site so it works better with the technology used by our visitors. For example, we may use this information to remember visitors to our Site, including so we have a history of user conversations with our online chat tool. We use this information to improve the content, functionality, and usability of this Site, and to better understand your needs and interests.
- We use information to communicate with you. We use Identifiers, Purchase Information, and Internet and Network Activity to:
- Respond to your requests or questions and provide you with effective customer service.
- Invite you to participate in surveys and provide us with feedback.
- Allow you to contact one of our dealers.
- Run sweepstakes, contests, and promotions, and notify you if you win.
- Communicate with you about your account or our relationship.
- We use information to verify requests made pursuant to this Policy. We will use Identifiers to verify your identity if you make requests pursuant to this Policy. The verification steps and the pieces of information that we request may vary depending on the sensitivity and nature of your request.
- We use information for hiring purposes. We use Identifiers and Employment-Related Information to review your job applications and contact you about employment opportunities. If you choose to voluntarily submit certain Employment-Related Information in connection with a job application, we will use that information in accordance with applicable law.
- We may use information from all of the categories described in Section 3 for the following purposes:
- Security, credit, or fraud prevention and to protect our company, our Sites, and our customers. This includes investigating and remediating fraud or other suspected illegal activity. For example, we may use information to detect intrusions into our network. We might share our server logs, which contain visitors’ IP addresses, with investigative authorities who could use that information to trace and identify you;
- Any purpose identified in an applicable Privacy Notice, click-through agreement or other agreement between you and us; and
- Any purpose permitted or required under applicable law.
5. How We Share Your Information
We share certain categories of personal information with the following entities and in the following circumstances:
- With Third–Party Vendors. We may share each category of personal information collected on this Site with third-party vendors and their suppliers, who act for us, or for our vendors, by providing services. For example, we may use third-party vendors to design and operate this Site; to conduct surveys; to send email; to help us store information, including on cloud servers, and to help us with promotions. We may also use vendors to help us carry out any purpose described in this Policy, or any Privacy Notice or other agreement we have with you. These third-party vendors may need each category of personal information to perform their functions.
- With Affiliate Dealers. With your consent, Triple E may share Identifiers collected through this Site with our independent dealers. These companies are permitted to use your information for their own marketing purposes. You may ask us to stop sharing this information with our independent dealers using the contact information below.
- With Our Business Partners and Other Third Parties. From time to time we may share Identifiers, Purchase Information, and Internet and Network Activity with business partners and other third parties. For example, we may work with third parties to co-sponsor contests or promotions, and we may share Identifiers you submit to participate in the contest or promotion with these third parties. We may share Identifiers, Purchase Information, and Internet and Network Activity with third parties whose products or services we think may interest you. These third parties may use this information for their own marketing purposes. Where permitted by law, or with your consent, these third parties may also share your information with others. Some transfers of your personal information to our business partners and other third parties may be viewed as a “sale” under certain state laws. You may ask us to stop sharing certain information with our business partners using the contact information below. We do not sell the personal information of minors between 13-16 years of age without affirmative authorization of the minor.
We share information from all of the categories described in Section 3 in the following circumstances:
- With a Successor Organization As Part of a Business Transfer. Your information may be transferred to a successor organization if, for example, we transfer the ownership or operation of this Site to another organization. We may also share your information if part of our business is sold, or if we merge with or are acquired by another organization.
- As Described in a Privacy Notice or click-through agreement.We may disclose your information as described in any Privacy Notice posted on this Site where you provide that information. By providing your information on that page you will be consenting to the disclosure of your information as described in that Privacy Notice. We may disclose your information as described in any click–through agreement to which you have agreed.
We may share non-personal information (e.g., in aggregate or de-identified form) for any purpose, unless prohibited by law. We use information collected through this Site to create a compiled, aggregate view of usage patterns. We may share aggregate information with third parties so they can better understand our user base. Third parties may use this information for analytical purposes and to market their own products and services. It is possible that third parties will attempt to “re-identify” de-identified data, and you should know that this is possible.
You should be careful when posting personal information or your location online. You understand and agree that any information you share publicly, including Identifiers, Purchase Information, and Location Information, may be copied, used, modified, or distributed by any other users, and that we cannot control this. You also understand that once you have posted or published such information, even if you delete it, it cannot always be removed from the internet, for example, if you or other users have shared or posted it to websites we do not control. Please consider carefully what information you choose to share. You should not post or publish sensitive information, such as financial information. You assume all risks associated with sharing your information as described in this section – including, but not limited to, any third party’s use of this information, or any disclosure of information that makes you or others personally identifiable, or that allows them to locate you.
6. Your Rights and Choices Regarding Your Personal Information
You have certain rights with regard to your personal information. You have the right to:
- Request that we disclose to you the following: (i) the categories of personal information that we have collected about you; (ii) the categories of sources from which we have collected personal information about you; (iii) the categories of personal information that we have disclosed about you for our business purposes and the categories of third parties to whom the personal information was disclosed, by category or categories of personal information for each third party to whom the personal information was disclosed; and (v) the specific pieces of personal information that we have collected about you.
- Request a portable copy of your personal information.
- Request that we delete personal information that we have about you, subject to certain exceptions allowed under applicable law.
- Not be discriminated against for exercising the above rights.
We may take reasonable steps to verify your identity prior to responding to your requests. The verification steps will vary depending on the sensitivity of the personal information and whether you have an account with us. We may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations. For example, we may retain personal information as permitted by law, such as for tax or other record keeping purposes, to maintain an active account, and to process transactions and facilitate customer requests. Employment-Related Information will not be included in fulfillment of your requests.
You may designate an authorized agent to make a request on your behalf. When submitting the request, please ensure the authorized agent is identified as an authorized agent.
You may exercise the above rights by calling our toll-free number at 1-877-992-9906, by submitting an online request here, or emailing us at [email protected]. We will respond to your request within the time limit set out by applicable law. We will use reasonable efforts to comply with your request as required by applicable law.
We respect your right to make certain other choices about how we collect, use, and disclose your information. We may ask you to make such choices when you provide your information. We also offer the additional choices outlined below:
Our Marketing Emails. You may opt-out of our marketing email using the “unsubscribe” function included in these emails. You may also contact us using the contact information provided below to ask not to receive email marketing. Even if you opt out of getting marketing messages, we may still send you transactional messages. These include responses to your questions.
Sharing information with third parties for their marketing purposes. To opt out of having us share your information with third parties for their marketing purposes, including our independently-owned dealers and our business partners, use the contact information below.
Collection of Geolocation Data. Your mobile device may allow you to adjust your settings so that location information is not available to any mobile website or application. If you have questions about the security and privacy settings of your mobile device, please refer to the instructions from your mobile service provider or the manufacturer of your device.
Changing your Preferences. You may be able to change other preferences on how we use your information through functionality provided through this Site. You can contact us at [email protected] if you have any questions or need help.
7. How We Protect Your Information
We take precautions to protect our Sites. Although we use measures to help protect your information against unauthorized use or disclosure, we cannot guarantee the security of information provided over the Internet or stored in our databases and will not be responsible for breaches of security beyond our reasonable control. You should use caution when using the Internet. This includes not sharing your passwords.
Personal information may be accessed by persons within our organization, or our third party service providers, who require such access to carry out the purposes indicated above, or for such other purposes as may be permitted or required by the applicable law. We manage personal information we collect from our offices in Winkler, Manitoba.
8. We may Transfer Personal Information to Other Countries
Some or all of the personal information we collect may be stored or processed on servers located outside your jurisdiction of residence, including in the United States. Data protection laws in the United States may differ from the laws where you live. As a result, this information may be subject to access requests from governments, courts, or law enforcement in those jurisdictions according to laws in those jurisdictions.
By providing us with personal information, you understand and expressly agree that we may transfer it outside of Canada or your jurisdiction of residence. If you do not agree to the transfer of your personal information to other countries, do not provide us with personal information.
9. These Sites Are Not Intended for Children
You must be at least 18 years old to use this Site. If you are 18, but a minor where you live, you must have the permission of your parent or legal guardian to use this Site. We do not knowingly collect, use or disclose personal information about visitors under 13.
If you are a parent or legal guardian and think your child under 13 has given us information, you can email us at [email protected]. You can also write to us at the address listed at the end of this policy. If you are a U.S. resident, please mark your inquiries “COPPA Information Request.”
Parents, you can learn more about how to protect children’s privacy on-line here.
10. Links to Other Websites
11. Correcting Your Information
If you would like to correct and update the personal information you have provided to us, please contact us at [email protected]. We will respond to your request within the time limit set out by the applicable privacy legislation. We will use reasonable efforts to comply with your request as required by applicable law.
To help protect against fraudulent requests to change your personal information, we may ask you for information to allow us to confirm that the person making the request is you or is authorized to change your information. For example, we may require you to verify your identity before we correct or update your personal information.
12. Additional Privacy Notices
We may amend or add to this Policy from time to time by giving you additional privacy notices (“Privacy Notices”), at the time we collect your information, and/or when you choose to take certain actions that affect the use or disclosure of your information. For example, certain pages of this Site may contain Privacy Notices providing more details about the information we collect on those pages, why we need that information, and choices you have about the ways we use or disclose that information.
13. This Policy May Change
We reserve the right to update or modify this Policy and any Privacy Notices, at any time, by posting the revised version of the Policy or Privacy Notice on this Site. We will notify you via a notice on our websites, and/or using any contact information you have provided to us of any material changes to our Policy, as required by law. Unless you otherwise agree, (for example, through a Privacy Notice), these changes will only apply to the information we collect after we have posted the revised Policy or Privacy Notice.
Your use of this Site following any such change constitutes your agreement that all information collected from or about you after the revised Policy is posted will be subject to the terms of the revised Policy. You may access the current version of this Policy at any time by clicking on the link marked “Privacy” on each page of the public areas of this Site.
14. Questions About This Policy or Triple E’s Data Practices
If you have questions or concerns about this Policy, any Privacy Notice, or Triple E’s data practices, please contact us using the following information: