VINLock's Privacy Policy
This policy outlines how VINLock protects, collects, uses and discloses personal information. This policy applies to VINLock's clients as well as individuals who have registered liened vehicles in Canada and the United States of America. To understand the meaning of "personal information" and other terms used throughout this policy, please refer to the Important Terms section.

VINLock has adopted a comprehensive management plan that addresses all aspects of information privacy and security, including accountability, authorization, data collection, usage and disclosure.

Protecting personal information
We safeguard the privacy of personal information through security measures appropriate to the sensitivity of the information.

Limiting the collection, use and disclosure of personal information
We collect information only by fair and lawful means.

We do not use or disclose personal information for purposes other than those for which it was collected, except with consent, or where permitted or required by law. We retain personal information only as long as necessary for these purposes.

Parties with whom we collect and exchange information
VINLock collects and exchanges personal information with various entities including:

• Government Agencies – Vehicle registry databases, law enforcement.
• Insurance Entities – insurers, brokers and others.
• Public and Private Lenders – banks and other financial companies.
• Car Rental Agencies

Identifying the purposes for personal information collection
We collect, use and disclose personal information when it pertains to:

• Vehicles registered with the DMV/Provincial Vehicle Registry
• Vehicles designated as insured or insurable
• Liened vehicles
• Establishing a vehicle owner's identity
• Protecting individuals, VINLock clients and ourselves from error and fraud
• Complying with legal and regulatory requirements

Using, disclosing and retaining personal information
We do not use or disclose personal information for purposes other than those for which it was collected. We retain personal information only as long as necessary for these purposes.

How long we retain personal information
The length of time we keep personal information will vary depending on the nature of the personal information as it relates to the length of time an individual owns and insures their vehicle, as well as the duration of the lein held by the leinholder. We have retention standards that meet legal and regulatory needs.

When an individual's personal information is no longer required, we securely destroy it or delete personally identifiable information.

Keeping Personal Information Accurate
We take care to keep the information in our records as accurate, complete and up to date as necessary for the purposes for which it is used.

How we protect personal information
We limit access to personal information and store it securely. Depending on the nature of the information, it may be stored in various secure computer systems owned by VINLock, or by the computer systems of the entities with which VINLock exchanges data.

We have security standards to protect our computer systems and personal information from unauthorized use or access. Our systems also protect personal information when it is electronically transmitted. We regularly audit our information security procedures and assess that they remain effective and appropriate.

Employees who have access to personal information are made aware of how to keep it confidential. Each employee must sign an agreement stating that maintaining confidentiality is a condition of employment with VINLock. Also, each year employees undergo a review of our Code of Conduct and certify they will abide by VINLock's ethical and professional standards including the obligation of confidentiality and privacy.

We use contracts and other measures with our clients to maintain the confidentiality and security of personal information and to prevent it from being used for any unauthorized purpose.

Access to personal information is only given to those individuals or entities who are permitted or required by law.

We regularly monitor our procedures and security measures to ensure that they remain effective and that they are being properly administered. Our Chief Privacy Officer is accountable for overseeing compliance with this policy.

Addressing Privacy Concerns
We are responsible for personal information under our control. There are designated individuals within VINLock who are accountable for compliance with these privacy principles.

We make available to the public information about our policies and practices related to managing personal information.

We address concerns about the privacy of the personal information we collect. We have steps individuals can follow if they have questions or concerns about their privacy.

How to resolve privacy concerns and complaints at VINLock

Step 1: Call Us
We are committed to upholding this policy. In most cases, a complaint or concern is resolved simply by talking to us about it. You should be able to get swift results by talking to a VINLock representative. You can speak with us by calling 416 850 4774.

Step 2: Write to Us
E-mail: privacy@vinlock.ca

Postal Address:

VINLock Chief Privacy Officer
35537-2528 Bayview Avenue
Toronto, ON M2L 2Y4

Be sure to include:

• your name and contact information where you prefer to be reached
• the nature of your complaint
• details relevant to the matter and with whom you have already discussed the issue
• Please note: If you choose to send us an e-mail, do not include sensitive information (for example, card or account numbers), as e-mail is not a secure method of communication.

Step 3: Contact the Privacy Commission of Canada
If the above steps fail to resolve your concern you may also contact the Office of the Privacy Commissioner of Canada:

Call toll free at 1 800 282-1376
www.privcom.gc.ca

Place de Ville
112 Kent Street, 3rd Floor
Ottawa, ON K1A 1H2

Important Terms Used in This Policy
When we refer to "personal information" it means information about an identifiable individual. This includes details such as age, identification numbers, financial information, and insurance-related information.

When we refer to "permitted or required by law", and "legal and regulatory" requirements, authority or restrictions, this includes law, regulation, rules or requests of the regulators or self-regulatory organizations which apply to VINLock (for example, the Privacy Commission of Canada).