PRIVACY POLICY (CANADA)

The following privacy policy provides an overview of how your data is collected, used and disclosed.

 

At GC Crédit-Bail Québec Inc., GC Leasing Ontario Inc., GL Leasing British Columbia Inc. (collectively "Grenke"), we are committed to maintaining the accuracy, confidentiality and security of your personal information. 

 

With the following information, we would like to give you an overview of how we process your personal information, what specific data is processed in detail, and how it will be used depends on the requested or agreed services.

 

It is Grenke’s policy to comply with the privacy legislation within each jurisdiction in which we operate. Sometimes the privacy legislation and / or an individual's right to privacy are different from one jurisdiction to another. This Privacy Policy covers only those activities that are subject to the provisions of Canada's federal and provincial privacy laws, as applicable. 

 

This Privacy Policy has a limited scope and application. Consequently, the rights and obligations contained in this Privacy Policy may not be available to all individuals or in all jurisdictions. If you are unsure if or how this Privacy Policy applies to you, please contact our Data protection officer for more information. 

 

1. Who is responsible for processing my personal information and who can I contact? 
 

You can reach our data protection officer at: 

 

GC Leasing Ontario Inc.

5600 Explorer Drive, Suite 302

Mississauga, Ontario, L4W 4Y2

Attention: Data Protection Officer

E-mail: service.toronto@grenke.ca

 

GC Crédit-Bail Québec Inc.

4605 boulevard Lapinière, Suite 280

Brossard, QC J4Z 3T5

Attention: Data Protection Officer

E-mail: service.montreal@grenke.ca

 

GL Leasing British Columbia Inc.

 138 East 13th Street, Unit 360

 North Vancouver, BC V7L 0E5

Attention: Data Protection Officer

 E-mail: service.vancouver@grenke.ca 

 

2. What sources and personal information do we use? 

 

We process personal information that we receive from our customers as part of our business relationship. In addition, we process – as far as necessary for the provision of our services and permitted under applicable law – personal information that we might collect from publicly accessible sources (e.g. debtor directories, land registers, trade and association registers, press, internet) or that was obtained from our distribution partners or from other third parties (e.g. a credit agency). 

 

Relevant personal information includes:

  • Personal details (name, address, birthday, place of birth and nationality)
  • Contact details (telephone, e-mail address)
  • Verification data (e.g. ID data)
  • Authentication data (e.g. signature sample)
  • Order data (e.g. payment order)
  • Data from the fulfilment of our contractual obligations (e.g. sales data in payment transactions)
  • Information about your financial situation (e.g. creditworthiness data, scoring/rating data, source of assets)
  • Advertising and sales data (including advertising scores), documentation data (e.g. consultation minutes) and other information comparable to the aforementioned categories.

 

3. Why do we process your personal information? 

 

a. For the fulfilment of contractual obligations 

 

Personal information is processed in order to provide financial services as part of the execution of our contracts with our customers or to carry out pre-contractual actions, which are carried out upon request. The purposes of doing so are primarily geared towards the specific product or service and may include, but are not limited to, needs analysis, consulting and to perform transactions. Further details on the purposes of processing personal information can be found in the relevant contract documents and terms and conditions. 

 

b. As part of the balance of interests

 

As far as necessary, we process your personal information beyond the actual fulfilment of the contract for the protection of our legitimate interests or those of third parties, in particular: 

 

  • Consultation and exchange of data with credit agencies to identify credit risk or default risk.
  • For the purposes of examining possible credit risks and default risks as well as preventing criminal offences, we provide EQUIFAX and GroupEcho with data on the application and the applicant. They will provide us with data stored on your person if we have credibly demonstrated our legitimate interest.
  • In addition, we transfer personal information collected in the context of a contract concerning the application, execution and termination of this business relationship as well as data on non-contractual or fraudulent behaviour to EQUIFAX.
  • The exchange of personal information with the credit bureaus may also serve the fulfilment of our rights and obligations (e.g. to carry out creditworthiness checks of customers). Credit agencies process the data obtained and also use it for the purposes of profiling (scoring).
  • Detailed information which may enable the pseudonymous analysis of the use of the website 
  • Review and optimisation of requirements analysis procedures for direct customer contact
  • Optimisation and needs-based design of the website
  • Advertising or market and opinion research, provided that you have not objected to the use of your data
  • Asserting legal claims and defence in legal disputes
  • Ensuring the IT security and IT operation of our organization
  • Prevention and investigation of criminal offences
  • Video surveillance for the protection of our rights, and for the collection of evidence in cases of robbery and fraud
  • Measures for building and facility safety (e.g. access control)
  • Measures to safeguard our rights
  • Measures for business management and further development of services and products
  • For the purposes of sending you advertising and marketing materials.

 

c. On the basis of your consent

 

Insofar as you have given us your consent to process your personal information for specific purposes (e.g., disclosure of data within the Group, analysis of payment transaction data for marketing purposes and/or creditworthiness check), the legality of this processing is assured on the basis of your consent. Consent that has been issued can be withdrawn at any time. The withdrawal of consent does not affect the legality of the data processed until the revocation.
 
d. Based on legal requirementslegitimate interests or in the public interest

 
In addition, we may be subject to various legal obligations (e.g., banking laws, money laundering laws and tax laws). The purposes of the processing of your personal information include, but are not limited to (i) verification of your identity and/or age; (ii) prevention of fraud and money laundering; (iii) the fulfilment of tax auditing; (iv) reporting obligations to Equifax; and (v) the assessment and management of risks.

 

4. Who receives my personal information?

 

Your personal information may be disclosed:

  • as permitted or required by applicable law or regulatory requirements;
  • to comply with valid legal processes such as search warrants, subpoenas or court orders;
  • as part of Grenke’s regular reporting activities to its affiliates;
  • to protect the rights and property of Grenke;
  • to the extent permitted by applicable law, during emergency situations where necessary to protect the safety of a person or group of persons; and
  • with your consent.

 

In particular, we may also share your personal information with our employees, contractors, consultants, affiliates, and other parties who require such information to assist us with managing our relationship with you, including: (i) third parties that provide services to us; and (ii) third parties that assist Grenke in the provision of services to you. For example, we may share your personal information from time to time with our third party information technology, data processing and payment processing service providers so that we may operate our business. We may also share your personal information with:

  • Public authorities and institutions (e.g. the tax and law enforcement authorities).
  • Other credit and financial services institutions or comparable institutions to which we transfer personal information over the course of our business relationship with you (depending on the contract, e.g., correspondent banks, credit agencies).
  • Other companies within our organization.

 

We may also share your personal information to our affiliates in order for them to contact you for the purposes of establishing or managing a business relationship with you.

 

Finally, your personal information may be disclosed or transferred to another party during the course of the grant of a security interest in Grenke’s assets, or completion of, all or a part of Grenke through, for example, an asset or share sale, or some other form of business combination, merger or joint venture, provided that such party is bound by appropriate agreements or obligations and required to use or disclose your personal information in a manner consistent with the use and disclosure provisions of this Privacy Policy, unless you consent otherwise.

 

5. Is my personal information transmitted to a third-party country or to an international organization?

 

A transfer of your personal information to organizations outside of Canada may take place from time to time for the purposes described in this Privacy Policy, or as far as

 

  • this is required in order to execute your orders (e.g. payment orders),
  • this is required by law (e.g. in order to comply with tax reporting obligations), or
  • you have given us your consent.

 

Accordingly, your personal information may be transferred to the European Union as well as the United States, potentially accessible to law enforcement and national security authorities of that jurisdiction. 

 

6. How is my data processed on the website?

 

Unless otherwise stated, we process your data on our website either to action your request or based on our legitimate interests as follows:

 

a. Usage data

 

Every time you access a webpage and retrieve a file, this process automatically saves general data to a log file. The storage is exclusively system-related and is purely for statistical purposes or to report criminal offences in exceptional circumstances.

 

We use this data to improve our websites and to present content tailored to your interests on various sites on the internet and on multiple devices. As part of this process, usage data is not merged with personalized data. Should you decide to provide us with your personal information, this data will be backed up securely during the entry process. The same applies to the storage in our system. For security reasons, we store your IP address. This can be accessed in case of a legitimate interest.

 

We do not save your browser history. A transfer of data to third parties or any other evaluation does not take place, unless there is a legal obligation to do so.

 

In detail, the following data record is saved for each access:

  • Device used
  • Name of the accessed file
  • Date and time of access
  • Time zone
  • Transferred data volume
  • Report as to whether the access was successful
  • Description of the type of web browser used
  • Operating system used
  • The previously visited site
  • Provider
  • User's IP address

 

b. Contact forms

 

In order to be able to give you the best possible advice as part of a request via our contact forms, the appropriate Grenke company that is best suited to respond to your request will be identified after inquiring about your specific interest at the top of the page. If you contact us (e.g. via contact forms), the designated company will save your data in order to process your request or in case any further correspondence is required. If several companies are listed there, they will process your personal information jointly. Further information on joint controllership can be obtained by sending an e-mail to any of the Grenke company using the contact information in Section 1 above. 

 

If you expressly agree to be contacted by e-mail, telephone or post within the scope of the contact form, you grant Grenke (and its affiliates, including GRENKE AG, GRENKE Business Solutions GmbH & Co. KG, GRENKEFACTORING GmbH and GRENKE BANK AG) the opportunity to inform you in future by telephone, e-mail or post about current products and services, in the selected category. We may also store your personal information for the purpose of sending you our newsletter. In addition, we store your IP address and the date of your registration in order to be able to prove your newsletter subscription in case of doubt. You can object to the use of your personal information for advertising purposes at any time or unsubscribe from the newsletter at any time by clicking on the unsubscribe link in the footer of the newsletter. 
 
If you do not give your consent, your personal information may, as further described in this Privacy Policy, be deleted after your request has been processed. Excluded from this is information for which legal or otherwise prescribed storage obligations exist.

 

Within the framework of our contact forms, we work with the Eloqua, a service of the provider ORACLE Nederland B.V., Hertogswetering 163, 3543 AS Utrecht, P.O. Box 40387, 3504 AD Utrecht, The Netherlands. For further information on the use of Eloqua, please refer to the additional notes under subsection (g) below.
 

c. Registration

 

The personal information provided during registration will only be used by us to enable you to use our services.

 

We collect the following data for the registration process:

  • E-mail address
  • User name
  • Password

 

d. Newsletter

 

Subject to your consent, we are happy to inform you about our latest news by sharing our newsletter with you.

 

In order to receive our newsletter, you must provide us with your name and e-mail address. You can also enter and submit further optional information. After you have submitted your e-mail address, you will receive an e-mail from us to the e-mail address you have specified, in which you must click a confirmation link to verify the e-mail address you provided.

 

Your personal information will be stored by us for the purposes of sending our newsletter. In addition, we store your IP address and the date of your registration in order to be able to prove the newsletter subscription (in case of doubt). In order to measure the success of our newsletter, we may collect data on whether the newsletter is opened, when it is opened and which links are clicked.

 

For the delivery of our newsletter, we work with the Eloqua service of the provider ORACLE Nederland B.V., Hertogswetering 163, 3543 AS Utrecht, P.O. Box 40387, 3504 AD Utrecht, The Netherlands. Newsletters sent with the help of Eloqua use tracking technologies. We use this data primarily to find out which topics are of interest to you by tracking whether our emails are opened and which links you click on. We may also use this information to improve the e-mails we send you and the services we provide, and to link them to existing tracking or profiling information. We will not be able to track your emails if you have disabled the display of images in your email program by default. In this case, however, the newsletter will not be displayed in full and you may not be able to use all the features. If you display the images manually, the above-mentioned tracking will take place. For further information on using Eloqua, please refer to the additional notes under subsection (g) below.

 

You can unsubscribe from the newsletter at any time by clicking the unsubscribe link at the bottom of the newsletter. 

 

e. Use of cookies

 

aa) General information

 

In order to make your visit to our websites more pleasant and to enable the use of certain functions, we use so-called cookies on various sites. These are small text files that are stored on your device. Some of the cookies we use are deleted after the end of the browser session, i.e. after closing your browser (so-called session cookies). Other cookies remain on your device and allow us or our affiliates to recognize your browser on your next visit (so-called persistent cookies).

 

Cookies cannot access other files on your computer or identify your email address.

 

bb) Use of cookies

 

Like most websites you visit, our website also uses cookies to improve the user experience on both one-time and repeated website visits. This allows you to quickly and easily switch between sites, save your configurations, and use third-party tools (such as YouTube videos) on the website.

 

Cookies are either placed on our website (first party cookies) or on other websites whose content appears on our website (third-party cookies). These third-party providers (such as Facebook) may set cookies if you are logged in to their pages and visit our website. We have no influence on the cookie settings of these websites. Please visit the third-party websites for more information on their use of cookies.

 

cc) Storage of cookies

 

The essential, functional and statistical cookies are stored on the basis of our legitimate interests for the optimization and design of our website.

 

Cookies are stored for marketing purposes on the basis of the user's consent. These cookies are therefore only set if the user agrees to the storage by issuing their consent to the cookie notification on the website.

 

dd) Deactivating and deleting cookies

 

The setting you choose on the first visit in response to the cookie notification will be saved. The selected settings can be adjusted here in the Privacy Settings at any time.

Call us

Get in touch with us via

Montréal:

+1 450 445 5270

Mo - Fr 8 am - 5 pm

Toronto:

+1 905 366 6000

Mo - Fr 8 am - 5 pm

Vancouver:

+1 778 357 06 80

Mo - Fr 8 am - 5 pm

Privacy Settings


Most browsers are otherwise set to automatically accept cookies. If the default settings for cookies are stored in your browser, all processes run in the background without any notifications. However, you can change these settings at any time.

 

You can set your browser so that you are informed about the setting of cookies and can decide on a case-by-case basis whether they are to be accepted or deactivated for specific cases or in general.

 

A general objection to the use of cookies for marketing or advertising purposes can be issued for a variety of services via the website http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. Furthermore, the prevention of cookies can be achieved by switching them off in your browser settings. Please note that this may mean you won’t be able to use all the features of this website.

 

ee) Overview of the cookies we use

 

Essential cookies

 

Essential cookies are required in order to be able to use our website as they enable basic functions such as site navigation and access to secure areas of the website. The website may not work properly without these cookies.

Name of the cookie
Purpose of the cookie
Storage time
Session or permanent cookie

Bloomreach

Technical cookie for the load balancer

Session duration

Session

Functional cookies

 

Functional cookies allow a website to store information that has already been entered (such as preferred language), and to provide the user with enhanced, more personalized features. Functional cookies are used for instance to enable requested functions such as playing videos. These cookies collect anonymised information; they cannot track your movements on other websites.

Name of the cookie
Purpose of the cookie
Storage time
Session or permanent cookie

Bloomreach

These cookies collect information that is either used to track the interests of our customers respectively our website users and to help improve the experience on their websites or to help us understand how our products and services are used.

12 months

Permanent

Statistical cookies

 

Statistical cookies collect information about the use of a website – such as the user’s most frequently visited pages and whether the user receives error messages when using a website. These cookies do not store information that allows the user to be identified. The information gathered is pooled and therefore evaluated anonymously. These cookies are used exclusively to improve a website's performance and thus the user experience.

Name of the cookie
Purpose of the cookie
Storage time
Session or permanent cookie

Piwik Pro
Piwik

Used to send data about the device and the visitor's behaviour to PIWIK.

30 minutes – 1 year

Session and permanent cookie

Piwik Pro
Piwik

To detect if a visitor has deliberately deactivated tracking.

Unlimited

Permanent

Cookies for marketing purposes

 

Cookies for marketing purposes are used to play targeted advertisements relevant to the user and adapted to their interests. They are also used to limit the frequency of an ad and to measure the effectiveness of advertising campaigns. They register whether you have visited a website or not. This information may be shared with third parties, such as advertisers. Cookies to improve targeting and advertising are often linked to third-party site functionalities.

 

 

Name of the cookie
Purpose of the cookie
Storage time
Session or permanent cookie

Facebook

These cookies enable behavioural advertising and analysis of Facebook

2 years

Permanent

Instagram

These cookies enable behavioural advertising and analysis of Instagram.

2 years

Permanent

Google Adwords

These cookies enable behavioural advertising and analysis on the Google AdWords platform.

30 days–2 years

Permanent

LinkedIn

These cookies enable behavioural advertising and analysis of LinkedIn

2 years

Permanent

Twitter

These cookies enable behavioural advertising and analysis of Twitter.

2 years

Permanent

Bloomreach

These cookies collect information that is either used to track the interests of our customers' users and to help improve the experience on their websites or to help us understand how our products and services are used.

12 months

Permanent

Eloqua

These cookies enable behavioural advertising and analysis within the context of email marketing and measuring the effectiveness of email advertising.

13 months

Permanent

f. Range analysis using Piwik

 

If you consent, we may use Piwik, a software for statistical evaluation of user access.

 

Your IP address will be hashed before it is saved. However, Piwik uses cookies that are stored on users' computers and enable the user’s use of the website to be analysed. In this case, pseudonymous usage profiles of the users can be created from the processed data. The information generated by the cookie regarding your use of this online content is stored on our server and not passed on to third parties. 

 

You can revoke your consent to this data processing as follows:

Privacy Settings


g. Use of Eloqua

 

We use the Eloqua service to collect statistical data about the use of our website, to send our newsletters and to optimize our services accordingly. The Eloqua servers of the supplier ORACLE Nederland B.V., Hertogswetering 163, 3543 AS Utrecht, P.O. Box 40387, 3504 AD Utrecht, Netherlands are located in the EU.

 

If you have consented to the use of cookies for marketing purposes, Eloqua will use corresponding cookies that are stored on your computer and that enable an analysis of the use of the website (hereinafter referred to as usage behavior). If you have already used a website that uses Eloqua, you may already have an Eloqua cookie. Even if this cookie is set on other websites, the information from your visit to our websites is only visible to us and is not shared with Oracle or any other users of the Eloqua system. It is also not possible for us to use this cookie to record or view information about your visits to any other websites.

 

If you enter personal information (e.g. in the contact form) during your visit to the website, these data will be processed with the usage behavior in order to offer you content on the website and in our newsletter that is geared to your interests, as well as to be able to send you news and information about our company or our range of services based on your data, which are geared to your individual interests. For this purpose, it is technically necessary that we combine your accrued and given data in user profiles and evaluate them for the aforementioned purposes. This is done internally and only for the aforementioned purposes.

 

The information generated by the cookie about your use of this website is transferred to a server and stored there. On our behalf, Eloqua uses this information to evaluate your use of the website and to compile reports on website activity. If you wish to prevent the use of Eloqua cookies or the evaluation of usage behavior on your device in the future, this is possible via the following link: Eloqua Opt-Out.

 

You can find further information on data protection in connection with the use of Eloqua here: Oracle Privacy Policy.

 

h) Integration of social media plug-ins

 

We are currently using the following social media plug-ins: Facebook, Instagram, Twitter, LinkedIn.

 

When you visit a page that contains such a plug-in, the browser will connect to the social media providers' servers and provide the information that you have accessed the corresponding sub-page of our website. In addition, the data referred to in paragraph 6a of this declaration will be transmitted, whereby in the case of Facebook, according to the respective providers in Germany, only an anonymous IP is recorded. This happens regardless of whether you have an account with this plug-in provider and are logged in there. If you are logged in to the plug-in provider, this data will be assigned directly to your account. If you click the button, the plug-in provider also stores this information in your user account and informs your contacts publicly. If you do not want your profile to be linked with the plug-in provider, you must log out before clicking the button. 

 

The plug-in provider stores this data as usage profiles and uses it for the purposes of advertising, market research and/or tailored website design. Such an evaluation is carried out in particular (also for non-logged-in users) to present needs-based advertising and to inform other users of the social network about your activities on our website. You have a right to object to the formation of these user profiles; but you must contact the respective plug-in provider to exercise them.

 

For more information on the purpose and scope of the data collection and its processing by the plug-in provider, please refer to the privacy statements of these providers, which can be found below. You will also find further information about your rights and settings options to protect your privacy here.

 

Addresses of the respective providers and URLs with their privacy policies:

 

 

i) Integration of Google Maps
 

We integrate the maps of the service "Google Maps" provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The data processed may include, but is not limited to, the IP addresses and location data of users, which, however, are not collected without their consent (usually performed as part of the settings of their mobile devices). Unless you have expressly consented to the use, our legal basis for this data processing is our legitimate interest in order to design our website to meet your needs. The data could also be processed in the USA. Privacy policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated

 

7. How long will my personal information be stored? 

 

Unless explicitly stated in this Privacy Policy, the usage and registration data stored with us is deleted as soon as it is no longer required for its intended use and the deletion does not conflict with any statutory retention obligations.

 

We process and store other personal information as long as it is necessary for the fulfilment of our contractual and legal obligations. It should be noted that our business relationship is a continuing obligation, which is designed to last for years. If the data is no longer required for the fulfilment of contractual or legal obligations, it is regularly deleted, unless its - temporary - further processing is necessary for the following purposes:

 

  • Fulfilment of commercial and tax-related retention obligations.
  • Preservation of evidence in the context of the statutory limitation periods. 

 

8. What rights do I have?
 

This Privacy Policy does not create or confer upon any individual any rights, or impose upon Grenke any rights or obligations outside of, or in addition to, any rights or obligations imposed by Canada's federal and provincial privacy laws, as applicable. Should there be, in a specific case, any inconsistency between this Privacy Policy and Canada's federal and provincial privacy laws, as applicable, this Privacy Policy shall be interpreted, in respect of that case, to give effect to, and comply with, such privacy laws.

 

9. How is my personal information protected?

 

Grenke endeavors to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to prevent your personal information from loss and unauthorized access, collection, use, disclosure, copying, modification, disposal or destruction. Unfortunately, we cannot guarantee complete security: for example, (i) unauthorized access, use, or disclosure, (ii) hardware or software failure, and (iii) other events may compromise the security of your personal information at any time.

 

The security of your personal information is important to us, please advise our Data Protection Officer immediately of any incident involving the loss of or unauthorized access to or disclosure of personal information that is in our custody or control. 

 

10. Am I obligated to provide my personal information?

 
As part of our business relationship, you must provide the personal information required in order to enter into a business relationship and perform its associated contractual obligations, or the personal information that we are required to collect by law. Without this information, we will generally not be able to conclude or execute the contract with you.
 
In particular, according to applicable laws, we may be obligated to identify you (or verify your identity) prior to entering into a business relationship with you on the basis of your identification document and to record and save your name, place of birth, date of birth, nationality, address and identification data. In order for us to be able to fulfil this legal obligation, you must provide us with the necessary information and documents and immediately notify us of any changes during the course of the business relationship. If you do not provide us with the necessary information and documents, we may not be able to enter into or continue your desired business relationship with us.

 

11. To what extent is there an automated decision-making process?

 
In principle, we do not use any fully automated decision-making processes in order to justify or maintain a business relationship with you. If we do use these procedures in individual cases, we will inform you about this separately, if required by law.

 

12. Does profiling take place?

 

We sometimes process your data automatically with the aim of evaluating certain personal aspects (profiling). For example, we use profiling in the following cases:

  • Due to legal and regulatory requirements, we are committed to combating money laundering, the financing of terrorism, and property-related offences. At the same time, data evaluations are also carried out (e.g. in payment transactions). These measures are also in place for your protection.
  • In order to provide you with targeted information and advice on products, we use evaluation tools. These enable needs-based communication and advertising, including market and opinion research.
  • We use the scoring to assess your creditworthiness. This calculates the probability with which a customer will meet their payment obligations in accordance with the contract. The calculation may include, for example, income, expenses, existing liabilities, occupation, employer, duration of employment, past business experience, past repayment of the loan, and information from credit reporting agencies. The scoring is based on a mathematically-statistically recognized and proven procedure. The calculated scores help us make decisions within the context of product sales and are part of ongoing risk management.

 

13. Your consent is important to us

 

It is important to us that we collect, use or disclose your personal information where we have your consent to do so. Depending on the sensitivity of the personal information, your consent may be implied, deemed (using an opt-out mechanism) or express. Express consent can be given orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from your action or inaction. For example, when you enter into an agreement with us, we will assume your consent to the collection, use and disclosure of your personal information for purposes related to the performance of that agreement and for any other purposes identified to you at the relevant time.

 

Typically, we will seek your consent at the time that we collect your personal information. In certain circumstances, your consent may be obtained after collection but prior to our use or disclosure of your personal information. If we plan to use or disclose your personal information for a purpose not previously identified (either in this Privacy Policy or separately), we will endeavor to advise you of that purpose before such use or disclosure.

 

We may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required to do so by applicable law or regulatory requirements. 

 

14. Withdrawal of Consent

 

1. Generally

 

You may change or withdraw your consent at any time, subject to legal or contractual obligations and reasonable notice, by contacting our Data Protection Officer using the contact information set out below. All communications with respect to such withdrawal or variation of consent should be in writing and addressed to our Data Protection Officer. In certain circumstances, the withdrawal of consent may render us unable to continue to provide products or services where the collection, use or disclosure of your personal information is necessary to provide the product or service.

 

To the extent permitted by applicable law, we assume that, unless you advise us otherwise, you have consented to the collection, use and disclosure of your personal information as explained in this Privacy Policy.

 

2. Direct advertising purposes

 
In individual cases, we process your personal information in order to perform direct advertising. You have the right to object at any time to the processing of personal information concerning you for such advertising, which includes profiling to the extent that it is related to such direct advertising.
 
If you object to the processing for direct advertising purposes, your personal information will no longer be processed for such purposes.
 
You can withdraw your consent to this by sending a correspondingly worded letter to any of the Grenke companies using the contact information in Section 1 above.

 

15. Revisions to this Privacy Policy

 

From time to time, we may make changes to this Privacy Policy to reflect changes in its legal or regulatory obligations or in the manner in which we deal with your personal information. We will post any revised version of this Privacy Policy on our website (at www.grenke.ca), and we encourage you to refer back to it on a regular basis.