Effective Date: December 9, 2019
Last Updated: January 3, 2024
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
- 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 may collect your business contact information. 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.
- Payment Information. We collect your credit card number and other financial account information. We call this “Payment Information.”
- How and where we collect Payment Information: We or our vendor(s) will collect this information from you if you make a purchase. Please do not provide us with sensitive information such as your credit card number, other payment information or health information using the live chat feature on our website, or using other insecure transfer mechanisms such as email. You should also not post this information to public areas of the Site.
- Purchase Information. We may collect your order history, such as what products you have purchased through our website. We may also collect your product and shopping preferences. We call this “Purchase Information.”
- How and where we collect Purchase Information: We or our vendor(s) will collect this information from you if you make a purchase.
- 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,” pixels, 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, the videos you view, 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 advertising and analytics partners, such as Google Analytics, Google Ads, 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. Learn more about these tools and how you can control them here.
- Location Information. We collect your general geographic location through your IP address and ZIP / postal code.
- How and where we collect Location Information: We also collect your general geographic location through your IP address, provided by your browser or device, and your ZIP / postal code.
- Audio, Electronic, Visual, or Similar Information. If you contact us, we collect information such as customer service interactions, call recordings, chat transcripts, files you attach, and email, text, chat, mail, or other correspondence. We call this information “Audio/Visual Information.”
- Employment-Related Information. If you apply for a job, 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, your citizenship or citizenship status, your immigration status, 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.
Some of the information described above may be considered “sensitive” under the laws of certain jurisdictions (including payment information, account login credentials, and some employment-related information) (“Sensitive Information”). Whether information is Sensitive Information will depend on the laws of your jurisdiction.
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, Audio/Visual Information, and general Location Information to provide the information, products and services you request, including to process payment, to show you dealers near you, and to deliver products and services.
- We use information for marketing purposes, including targeted advertising. We use Identifiers, Purchase Information, and Internet and Network Activity Information, and general Location Information for marketing and to advertise to you, including to contact you with special offers and other information (including third party offers or products) we think may interest you. We also use this information to improve our marketing and promotional efforts. To learn about your choices for these communications, read the “choices” section below. We and our third-party advertising partners use Identifiers, Purchase Information, and Internet and Network Activity Information to display and serve you targeted advertising, cross-context behavioral advertising, and interest-based advertisements about products and offers, both on our Site, and on other websites. We may also use this information to advertise to people who may share interests or characteristics we think are similar to yours. For example, we may share hashed information with social media for the purpose of creating custom audiences and delivering our advertisements to members of the social media site. Such members may be served advertising when the social media site matches our data to its data. For more information, including how to opt-out of some advertising, please read our About Our Ads disclosure and visit Section 6, “Your Rights and Choices,” below.
- We use information to improve our products and services. We use Identifiers, Purchase Information, Internet and Network Activity, Audio/Visual Information, and general 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, Audio/Visual Information and general 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 Audio/Visual Information for quality and training purposes. We use this information to improve the content, functionality, and usability of this Site, and to better understand your needs and interests. Learn more about specific tracking tools we use and how you can control some of them here.
- We use information to communicate with you. We use Identifiers, Purchase Information, Audio/Visual Information, and Internet and Network Activity to:
- Respond to your requests or questions and provide you with effective customer service. We may also use Payment Information to identify a particular transaction and make payment adjustments.
- 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.
- Process your application for employment with us.
- 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 use sensitive personal information for reasonably expected purposes. We use sensitive personal information to provide you with products and services and in connection with your requests (i.e., to fulfill purchases and allow account logins). We use Employment-related Information that is defined as “sensitive” under applicable laws in connection with your employment application. We also use sensitive personal information as authorized by 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.
- We may use de-identified or aggregate information. We may use de-identified or aggregated data for any purpose, unless prohibited by 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 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 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. We may share Identifiers, Purchase Information, and Internet and Network Activity with advertising networks, social media platforms, data brokers, and ad tech companies when we allow them to place tracking tools on our brands’ websites or in our digital ads. We may disclose certain of your personal information, such as a hashed version of our email list, or other contact lists, to third parties such as social media sites. We do this to better serve our advertising, both to you, and to others, such as people who may have interests that we, or the social media site, believe may be similar to yours. 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” or “targeted advertising” under certain state laws. For more information, see the “Your Rights and Choices” section below and visit Do Not Sell or Share My Personal Information. You may also ask us to stop sharing certain information with our business partners using the contact information below. We do not knowingly sell or share the personal information of minors between 13-16 years of age.
We share information from all of the categories described in Section 3 in the following circumstances:
- Within the Triple E Family of Companies, including with our parent, subsidiary, and affiliated companies.
- With Third-Party Social Media Platforms. The Site may have features that allow you to post information about the actions you take on this Site to a third-party social media platform (such as Facebook or Twitter). If you choose to use this functionality, people with access to your profile on the third-party platform may be able to see the actions you have taken—for example, the items you have purchased. Thus, you should have no expectation of privacy in those actions. Further, if you choose to link your profile on this Site with an account on a third-party social media platform, we may share the information in your profile with that third-party platform.
- 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. However, we do not attempt to re-identify de-identified data, except as permitted or required by law.
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, UGC, and general 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 access to your personal information, including the specific pieces of personal information that we have collected about you.
- Request a portable copy of your personal information.
- Request that we correct inaccurate personal information collected from you, subject to certain exceptions allowed under 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.
- Request that we delete personal information that we have about you, subject to certain exceptions allowed under applicable law. Please note that your information may not be deleted in its entirety from our systems, and some information may be kept to comply with legal exceptions or obligations. We will also keep a copy of your request and information as required by law.
- Opt out of the “sale” or “sharing” of your personal information to third parties, or use of your personal information for “targeted advertising” as these terms are defined under applicable laws. Click the following link for more information and to opt out: Do Not Sell or Share My Personal Information. We respond to certain opt-out preference signals to the extent required by applicable law for your browser or device, but we cannot link this information to your account. Your selections are specific to the device, website, and browser you are using, and are deleted whenever you clear your browser’s cache.
- Request to revoke your prior consent or confirm the processing of your personal information.
- Appeal certain decisions related to your privacy rights requests.
- 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.
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 us at 1-204-325-4345, 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. For our notice at collection, see Sections 2 – 5 and 7 of this Policy.
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 and in our About Our Ads disclosure:
Financial Incentives: From time to time, we may offer financial incentives in connection with the collection or use of personal information. The material terms of the financial incentive will generally be presented to you at the time you sign up. You may withdraw from any financial incentive at any time by emailing us at [email protected].
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 and Retain 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.
We will retain information for as long as it is reasonably needed or permitted in light of the purposes for which we collected it. We also retain information as required by law. The criteria we use to determine our retention policies include the length of our relationship with you, your requests, your continued use of our Sites, ongoing obligations such as contracts and services, and our legal obligations.
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. 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.
12. 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.
13. 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: