Your privacy is important to Snap Auto Wheels Ltd. (“Snap Auto Wheels”). This Privacy Policy explains how Snap Auto Wheels collects, uses, discloses, and retains personal information, including information collected by Snap Auto Wheels through websites and telephone calls and when providing products or services.
 

1. Your Consent
   By providing Snap Auto Wheels with your personal information, you consent to the collection, use, disclosure, and retention of that information by Snap Auto Wheels in accordance with this Privacy Policy and as otherwise permitted by applicable law. You may withdraw your consent at any time, subject to legal or contractual restrictions and on reasonable notice to Snap Auto Wheels, but then you might not be able to proceed with your intended interactions or transactions with Snap Auto Wheels or otherwise receive the full benefit of Snap Auto Wheels’ products and services.
    

2. Personal Information
   In this Privacy Policy, “personal information” means information about an identifiable individual, such as an individual’s name and email address, but does not include (to the extent permitted by law) information that is publicly available in a telephone directory or that is business contact information that enables an individual to be contacted at a place of business.
    

3. Information That Snap Auto Wheels Collect
   (a) Information You Provide
   You may be asked to voluntarily give your personal information to Snap Auto Wheels when you interact, orally, in writing or by electronic transmission, with Snap Auto Wheels, including when you apply for an account, subscribe to a newsletter, register to receive information, apply or register for or order a product or service offered by Snap Auto Wheels or use a product or service provided by Snap Auto Wheels. In those circumstances, you can choose not to provide certain requested personal information, but then you might not be able to proceed with your intended interaction or transaction with Snap Auto Wheels or otherwise receive the full benefit of the desired product or service. Telephone calls between you and Snap Auto Wheels will be recorded to ensure accuracy and quality assurance, and may be disclosed to third parties to verify Snap Auto Wheels is compliant with its contractual obligations to third parties. You can choose not to have the telephone call recorded and communicate by writing or electronic transmission.
   
   (b) Automated Collection
   A Snap Auto Wheels Company may automatically collect certain information regarding your use of the Snap Auto Wheels Company’s website or online service, such as the dates and times that you access the website or online service, the browsers, operating systems, software, and devices that you use to access the website or online service, and details of your use of the website or online service. Snap Auto Wheels’ website, online services, email messages, and advertisements may use technologies (e.g., cookies, web beacons, tokens, session recording, pixels or tags) to collect information that assists Snap Auto Wheels in improving its products, services, customer communications, and advertising, and to prevent fraud. Snap Auto Wheels may use information that it collects through technological means to recognize you as a user of Snap Auto Wheels’ website or online services, to facilitate and improve your use of Snap Auto Wheels’ website or online services, to confirm that messages have been delivered to and opened by you, and to provide you with targeted advertisements. You may choose to decline or disable cookies if your web browser or device permits, but doing so may affect your ability to access or use certain features of a website or online service. Much of the information that is automatically collected by technological means is non-personal information (because the information does not identify you), and Snap Auto Wheels will deal with that non-personal information as explained below in this Privacy Policy unless applicable law requires otherwise.
   
   (c) Credit Reports
   When you apply or register for, order, or use certain products or services from Snap Auto Wheels (e.g., referral to lender), Snap Auto Wheels may obtain, and continue to periodically obtain, your credit score and related information from a credit reporting agency to process or fulfill the transaction and to update your confidential profile for use by Snap Auto Wheels for purposes as set out in this Privacy Policy. Upon your request, we will inform you if we have ordered such a report or reports and will give you the name and address of the credit reporting agency that furnished the report or reports. You also acknowledge and agree that any dealers or other persons or organizations to which we have disclosed your personal information in accordance with this Privacy Policy may request a credit report for any legitimate purpose associated with your application for credit, extending credit, making product offers, modifying the terms of your credit agreement, collection on your account, or similar services or products.
   
   (d) Bank Information
   When you use the bank account verification system (“Bank Verification System”) from within Snap Auto Wheels’ website, Snap Auto Wheels may, in accordance with this Privacy Policy and Snap Auto Wheels’ General Terms of Service, retrieve your bank account information, including your transaction history (but not your bank account log-in credentials) for purposes as set out in this Privacy Policy. Snap Auto Wheels may use the Bank Verification System to periodically obtain your updated bank account information to update your confidential profile for use by Snap Auto Wheels for purposes as set out in this Privacy Policy.For clarity, you acknowledge and agree that Snap Auto Wheels may periodically retrieve your bank account information and disclose the bank account information to independent businesses, including Snap Auto Wheels Companies, or Snap Auto Wheels’ or Snap Auto Wheels Companies’ suppliers or service providers, for purposes as set out in this Privacy Policy.
   
   (e) Information Regarding Referred Transactions
   If Snap Auto Wheels refers you to an independent business (e.g., a lender, dealership, insurance provider) for a proposed transaction (e.g., a vehicle loan, vehicle purchase, insurance purchase), then Snap Auto Wheels may collect from that independent business information regarding the transaction to update your confidential profile for use by Snap Auto Wheels as set out in this Privacy Policy.
    

4. How Snap Auto Wheels Uses Personal Information
   (a) General
   Snap Auto Wheels uses your personal information collected by Snap Auto Wheels for purposes relating to or arising from your relationship and transactions with Snap Auto Wheels and as otherwise set out in this Privacy Policy or permitted by applicable law, including:
   • to administer your relationship with Snap Auto Wheels, including to create and manage your account with Snap Auto Wheels and to contact and correspond with you regarding those matters;
   • to facilitate your interactions and transactions with Snap Auto Wheels, including to process your applications, requests, orders and payments;
   • to provide products and services to you;
   • to process and respond to your inquiries, requests and other communications;
   • to provide you with information (including by email and other electronic messages) regarding Snap Auto Wheels and its products and services and related products and services offered by other businesses, to the extent permitted by applicable law;
   • to administer and facilitate your participation in contests and promotions related to Snap Auto Wheels;
   • to maintain, protect, and improve Snap Auto Wheels’ products and services and to develop new products and services;
   • to protect and enforce Snap Auto Wheels’ legal rights, interests, and remedies and to protect the business, operations, and customers of Snap Auto Wheels or other persons; and• to assist Snap Auto Wheels Companies to collect, use, disclose, and retain your personal information in accordance with this Privacy Policy.
   
   (b) Disclosure by Snap Auto Wheels
   Snap Auto Wheels may share your personal information with Snap Auto Wheels Companies, and Snap Auto Wheels may develop, maintain, and share a confidential profile of you for use by each Snap Auto Wheels Company to provide information, products, and services to you, to facilitate your dealings with each Snap Auto Wheels Company, and as otherwise set out in this Privacy Policy.
   
   (c) Interest-Based Advertising
   Snap Auto Wheels may use interest-based advertising services (sometimes called “remarketing” or “retargeting”) provided by third-party vendors (such as Google and Facebook) to display advertisements on third-party websites and social media sites visited by users of Snap Auto Wheels’ website. Advertising vendors (such as Google and Facebook) use cookies, pixels, or tokens – unique identifiers of a web browser on a specific computer that are installed on the computer when it accesses Snap Auto Wheels’ website – to display ads based on the computer’s past access to Snap Auto Wheels’ website. You can opt-out of Google’s use of cookies by visiting Google’s Ads Settings. You can also opt-out of a remarketing vendor’s use of cookies by visiting the Network Advertising Initiative’s consumer opt-out page.
    

5. How Snap Auto Wheels Discloses Personal Information
   (a) GeneralSnap Auto Wheels discloses your personal information for purposes relating to or arising from your relationship and transactions with Snap Auto Wheels and as otherwise set out in this Privacy Policy or permitted by applicable law.
   
   (b) Specific Consents
   Snap Auto Wheels may disclose your personal information in accordance with express or implied consents that you give during your interactions and transactions with Snap Auto Wheels.
   (c) Referred Transactions
   If Snap Auto Wheels refers you to an independent business (e.g., a lender, dealership, insurance provider) for a proposed transaction (e.g., a vehicle loan, vehicle purchase, insurance purchase), then Snap Auto Wheels may disclose your personal information (including your credit score that you provided to Snap Auto Wheels, bank account information, and related information) to the independent business to facilitate the proposed transaction. Snap Auto Wheels has no responsibility or liability for the use, disclosure, or retention of your personal information by the independent business, and the use, disclosure, and retention of the disclosed information by the independent business is not subject to this Privacy Policy.
   
   (d) Suppliers and Service Providers
   Snap Auto Wheels may disclose your personal information to its suppliers and service providers (including fraud prevention services and payment processors) to assist Snap Auto Wheels in the provision of information, products, and services to you, to provide services to Snap Auto Wheels, to assist Snap Auto Wheels in using your personal information as set out in this Privacy Policy and as otherwise permitted by applicable law.
   
   (e) Law Enforcement/Legal Disclosures
   Snap Auto Wheels may disclose your personal information as required or authorized by applicable law, including to comply with a subpoena, warrant, court, arbitral order, or litigation disclosure obligation. Snap Auto Wheels may disclose your personal information to law enforcement agencies or other independent organizations if Snap Auto Wheels reasonably believes the disclosure is necessary or appropriate in connection with national security, law enforcement, or other issues of public importance, or if Snap Auto Wheels reasonably believes the disclosure is necessary or appropriate to protect and enforce Snap Auto Wheels' legal rights, interests, and remedies, or to protect the rights, interests, business, operations, or customers of Snap Auto Wheels or other persons (including to detect and prevent fraud and other illegal activities, enforce any of the terms of use, terms of service or other agreements that govern access to or use of any of Snap Auto Wheels' products or services). Snap Auto Wheels has no responsibility or liability for the use, disclosure, or retention of your personal information by the agencies, independent organizations, or other persons to whom Snap Auto Wheels discloses the information in the foregoing circumstances, and the use, disclosure, and retention of the disclosed information by those agencies, independent organizations, or other persons are not subject to this Privacy Policy.
   
   (f) Business Transactions
   Snap Auto Wheels may disclose your personal information in connection with a proposed or actual business transaction in which Snap Auto Wheels is involved (such as a corporate amalgamation, reorganization, merger, or acquisition, or the sale or transfer of some or all of Snap Auto Wheels' business or assets), but Snap Auto Wheels will require the information recipient to agree to protect the privacy of your personal information in a manner that is consistent with this Privacy Policy and applicable law.
    

6. Location of Personal Information
   Snap Auto Wheels and Snap Auto Wheels Companies, and and their service providers may process, store, and use your personal information at facilities in various countries, including Canada, the United States of America, and one or more countries in Europe or Asia. The personal information protection laws of those other countries might be different from the laws of the jurisdiction in which you reside and might permit courts, government, law enforcement agencies, regulatory agencies, and security authorities to access your personal information without notice. By providing your personal information to Snap Auto Wheels, you consent to the transfer of the personal information to facilities located in other countries and the processing and storage of the personal information at those facilities.
    

7. Retention of Personal Information
   Snap Auto Wheels retains your personal information for the period reasonably necessary for the purposes set out or referenced in this Privacy Policy and to comply with Snap Auto Wheels' legal obligations or enforce or protect Snap Auto Wheels' legal rights, or a longer period required or permitted by applicable law. Snap Auto Wheels will delete or dispose of your personal information when Snap Auto Wheels is no longer reasonably required to retain the information for the purposes set out or referenced in this Privacy Policy.
    

8. Protection of Personal Information
   Snap Auto Wheels uses reasonable safeguards – including administrative, physical, and technical security and safeguarding measures – appropriate to the sensitivity of the personal information in Snap Auto Wheels' possession or under Snap Auto Wheels' control to help protect the information from unauthorized access, collection, use, disclosure, disposal, or similar risks. Nevertheless, security risks cannot be eliminated and Snap Auto Wheels cannot guarantee that your personal information will not be used, disclosed, or deleted in ways not otherwise described in this Privacy Policy.
    

9. Accuracy, Access, and Deletion of Personal Information
   (a) Accuracy
   Snap Auto Wheels will rely on you to ensure that the personal information that you provide to Snap Auto Wheels is as accurate, complete, and up-to-date as necessary for the purposes for which Snap Auto Wheels uses the personal information. You will promptly notify Snap Auto Wheels of any changes to your personal information using the procedures made available for that purpose by Snap Auto Wheels or by contacting Snap Auto Wheels' customer service.
   
   (b) Access
   You may reasonably request access to your personal information collected by Snap Auto Wheels and information about Snap Auto Wheels' use, disclosure, and retention of that personal information by submitting a written request to Snap Auto Wheels' Privacy Officer using the contact information noted below. Subject to applicable exceptions and limitations prescribed by applicable law, you will be given reasonable access to your personal information and you will be entitled to verify the accuracy and completeness of your personal information and to have the information revised as appropriate. You may be required to pay a reasonable fee for access to your personal information.
   
   (c) Deletion
   You may request Snap Auto Wheels delete your personal information in its possession by submitting a written request to Snap Auto Wheels' Privacy Officer using the contact information noted below. Subject to applicable exceptions and limitations prescribed by applicable law, Snap Auto Wheels will delete your personal information. Snap Auto Wheels will take appropriate steps to verify the identity of anyone requesting changes to, access to, or deletion of the individual’s personal information. Snap Auto Wheels may decline to process a request to change or access personal information that is unreasonably repetitive, frivolous, vexatious, or impracticable, that infringes or jeopardizes the privacy of other persons, or for other reasons permitted by applicable law.
    

10. Non-Personal Information
    Snap Auto Wheels may collect, use, disclose, and retain non-personal information (information that is not about an identifiable individual), including to generate data analytics and business intelligence to better understand and improve Snap Auto Wheels' business, websites, and services, and to enhance the customer experience. Snap Auto Wheels may use aggregated, anonymous, or de-identified data to help identify patterns and trends in the use of its services.
     

11. Other Websites and Businesses
    Snap Auto Wheels' websites and online services may contain links to other websites or online services operated by other businesses. This Privacy Policy does not apply to the collection, use, disclosure, and retention of your personal information by those websites or online services. The collection, use, disclosure, and retention of your personal information by those websites or online services are governed by the privacy policies of those other websites or online services. Snap Auto Wheels encourages you to review the privacy policies of other websites and online services.
     

12. Social Media and Similar Situations
    When you use certain aspects of Snap Auto Wheels' websites or services to post information to social media platforms (e.g., there may be links to Snap Auto Wheels’ social media accounts or you may be able to post information about your experience with Snap Auto Wheels to your own social media pages), other persons may see the personal information that you post. When you link your Snap Auto Wheels account with your social media account, Snap Auto Wheels may collect, use, disclose, and retain personal information relating to you and your use of those social media platforms as set out in this Privacy Policy and as permitted by applicable law. Please remember that any information you post to social media platforms is not subject to this Privacy Policy.
     

13. Updates to this Privacy Policy
    Snap Auto Wheels may change this Privacy Policy from time to time by posting a new version of the Privacy Policy on its website. Snap Auto Wheels' collection, use, disclosure, and retention of your personal information will be governed by the version of the Privacy Policy in effect at that time. If the changes are material, Snap Auto Wheels will take reasonable steps to notify you, such as by posting a notice on its website or by sending you an email.
     

14. Contacting Snap Auto Wheels' Privacy Officer
    If you have any comments or questions about this Privacy Policy or how Snap Auto Wheels deals with your personal information, or if you wish to make a request regarding your personal information, please contact Snap Auto Wheels' Privacy Officer at: matt@snapautowheels.com
    
    Snap Auto Wheels will respond to your inquiry within the time periods prescribed by applicable law.