Privacy Policy

Summary — Please Read This First

Auto Lending Canada is a marketing, lead generation, and referral business. We are not a lender, bank, credit grantor, insurer, or licensed motor vehicle dealer, and we do not ourselves provide financing or sell vehicles.

In plain language, here is how our business works and what happens to your information:

• When you submit an inquiry or application through our website, we collect the personal information you provide (such as your name, contact details, location, vehicle preferences, employment, and income information).
• We share, transfer, and sell that information — for compensation — to our affiliated companies and to third-party businesses, including automotive dealers, lenders, brokers, finance companies, and providers of related products and services, so that they can contact you and offer you financing, vehicles, and related products and services.
• We are paid by these companies for referring you or providing your information to them. This compensation is how our business earns revenue and is why our service is free to you.
• Once your information is provided to a third party, that third party is responsible for its own use of your information under its own privacy policy.
• You may withdraw your consent at any time, subject to the limits described below, by contacting us at privacy@autolendingcanada.ca.

The rest of this Privacy Policy explains this in detail. By submitting your information through our website, you expressly consent to the collection, use, disclosure, and sale of your personal information as described in this Privacy Policy. If you do not agree, please do not submit personal information to us.

1. Who We Are and Scope of This Policy

This Privacy Policy ("Privacy Policy") describes how Auto Lending Canada Ltd., doing business as Auto Lending Canada, together with its parent companies, subsidiaries, and affiliated companies under common ownership or control, including Deal Zone Auto Ltd. and Allstar Auto Finance Ltd. (doing business as Approvals Canada) (collectively, "Auto Lending Canada," "ALC," "we," "us," or "our"), collects, uses, discloses, sells, and protects personal information.

This Privacy Policy applies to:

• our website at autolendingcanada.ca and any related pages, forms, funnels, or landing pages we operate (the "Website");
• information you provide to us by phone, email, SMS/MMS, chat, social media, or any other channel; and
• information we receive about you from third parties as described below.

"Personal Information" means information about an identifiable individual, as defined by applicable law, including the federal Personal Information Protection and Electronic Documents Act (PIPEDA), British Columbia's Personal Information Protection Act (BC PIPA), Alberta's Personal Information Protection Act, and, for residents of Quebec, the Act respecting the protection of personal information in the private sector as amended by Law 25.

Any capitalized terms not defined in this Privacy Policy have the same meaning as in our Terms of Use, available on our Website. This Privacy Policy is incorporated into and forms part of our Terms of Use.

2. Our Business Model: Lead Generation, Referrals, and the Sale of Leads

It is important that you understand what we do:

(a) We are a lead generation and referral platform. We do not lend money, issue credit, sell vehicles, or provide insurance. When you submit an inquiry or application, you are not applying for credit directly with us; you are asking us to connect you with businesses that may be able to help you.

(b) We transfer and sell the information you submit. When you submit your information, we may, at our discretion:

• transfer your information to one or more of our affiliated companies, which may use it for their own business purposes as described in this Privacy Policy, including operating customer relationship management systems, contacting you, and matching you with financing and vehicle options;
• provide, license, or sell your information to one or more third-party businesses ("Partners"), including automotive dealerships, dealer groups, lenders, banks, credit unions, finance companies, loan brokers, and lead aggregators or lead marketplaces that in turn distribute leads to such businesses; and
• provide, license, or sell your information to third-party providers of products and services related to vehicle ownership and personal finance, including providers of vehicle insurance, extended warranties and vehicle protection products, roadside assistance, vehicle history and valuation services, refinancing, credit monitoring, credit building, and debt management services.

(c) We are compensated for your information. We receive fees, commissions, or other compensation from affiliates and Partners in exchange for referrals and for providing your information to them. The amount and structure of compensation varies and may influence which Partners receive your information. We do not charge you for our service; our compensation comes from affiliates and Partners.

(d) Partners act independently of us. Any credit decision, financing offer, vehicle sale, insurance policy, or other product or service is provided by the affiliate or Partner, not by us, under that party's own terms and privacy policy. Each Partner that receives your information is independently responsible for maintaining its own records of consent and for complying with applicable law in its communications with you.

3. Personal Information We Collect

Information you provide to us

We collect Personal Information when you voluntarily provide it, including when you:

• complete or partially complete any application, pre-approval, quote, "Apply Now," "Get Pre-Approved," "Sell My Car," or similar form on our Website (including information you enter even if you do not click the final submit button, to the extent it is transmitted to us as you progress through the form);
• contact us through our "Contact Us" page, by phone, email, SMS/MMS, chat, or social media; or
• otherwise provide information to one of our representatives.

The Personal Information you provide may include:

• your full name and date of birth;
• contact information, such as your address, postal code, telephone number, and email address;
• information relevant to your financing request or creditworthiness, such as employment status, employer, occupation, income, housing status and costs, and other financial details you choose to submit or authorize to be collected;
• information about your current vehicle, including make, model, year, VIN, mileage, condition, accident history, and information needed to assess trade-in or sale value;
• your vehicle purchase preferences, desired payment range, and timing;
• information regarding your vehicle insurance, registration, and driving history; and
• any other Personal Information you choose to submit.

Advantage and Referral Program information

Every submission automatically activates membership in the Auto Lending Canada Advantage program at no charge. If you participate in our Referral Program as a referrer, we collect referral attribution information — your name and the contact details we use to match a referral to your file — together with the payment details needed to send your reward, such as the email address used for Interac e-Transfer, and records of referrals made and rewards paid.

If another person refers you to us through our referral form, we receive your name and contact information from that person, who has confirmed to us that they know you personally and have your permission to share it. We use that information only to send you a single invitation message that identifies the person who referred you and invites you to apply, and to recognize the referral if you later apply. We do not sell this information, do not use it for any other marketing, and will not contact you again unless you respond or submit an application. If you do not submit an application within ninety (90) days, we delete it.

Information we collect automatically

When you use our Website, we automatically collect certain information through cookies, pixels, software development kits, server logs, and similar technologies, including: IP address and approximate location; device and browser type and settings; operating system; pages viewed, links clicked, forms started and completed, and time spent; referring website addresses and campaign parameters (such as UTM codes and advertising click identifiers, including Google gclid and Meta fbclid); session replay and user-experience data; and device or advertising identifiers. See Section 8 (Cookies, Tracking, and Advertising).

Information we receive from third parties

We may receive information about you from third parties, including:

• credit bureaus such as Equifax and TransUnion, and financial institutions, where you have provided the authorization required by law;
• our affiliates and Partners, including confirmation of contact, application status, approval or funding status of a referral (used for our records, compensation reconciliation, analytics, and advertising measurement);
• advertising, analytics, and measurement providers;
• identity, phone number, and fraud verification services (for example, services that verify that a phone number is active, Canadian, and of a particular line type); and
• publicly available sources.

4. How We Use Personal Information

We use Personal Information for the following purposes:

• to operate our lead generation and referral business, including reviewing your inquiry, matching you with affiliates and Partners, and transferring or selling your information to them as described in Section 2 and Section 5;
• to contact you by phone, email, SMS/MMS, and other channels about your inquiry, your options, and the status of your request, including through automated systems;
• to provide, personalize, and improve the Website, including remembering your progress in an application;
• to verify your identity and contact information and to detect and prevent fraud, bots, and abusive submissions;
• to measure, analyze, and improve our marketing and advertising, including matching submitted information with advertising platforms for conversion measurement and audience building (see Section 8);
• to send you marketing and promotional communications where permitted by law and consistent with your consent (see Section 7);
• to administer, reconcile, and audit compensation with affiliates and Partners;
• to administer the Auto Lending Canada Advantage program and our Referral Program, including matching referrals to files, sending a single referral invitation to a person you refer, tracking qualified referrals, and paying referral rewards;
• to maintain business records, comply with legal obligations, respond to legal process, and establish, exercise, or defend legal claims, including maintaining records of the consents you provide and of the parties to which your information was disclosed; and
• for any other purpose disclosed to you at the time of collection or to which you consent.

We collect, use, and disclose the Personal Information reasonably necessary to fulfill these purposes.

5. How We Disclose and Sell Personal Information

We disclose, transfer, and sell Personal Information to the following categories of recipients:

(a) Affiliated companies. Companies that are under common ownership or control with Auto Lending Canada, including Deal Zone Auto Ltd. and Allstar Auto Finance Ltd. (doing business as Approvals Canada) and any other current or future affiliates. Affiliates may use your information for the purposes described in this Privacy Policy, including operating CRM and lead management systems, contacting you, and offering you financing and related products and services.

(b) Automotive and financing Partners. Automotive dealerships and dealer groups; lenders, banks, credit unions, and finance companies; loan brokers and financing intermediaries. These Partners may contact you, assess your eligibility, obtain one or more credit reports where you have separately provided the authorization required by law, and offer you financing and vehicles.

(c) Related product and service Partners. Providers of products and services related to vehicle ownership and personal finance, including vehicle insurance; extended warranty and vehicle protection products; roadside assistance; vehicle history, inspection, and valuation services; vehicle purchasing services (for sell-your-car requests); refinancing; credit monitoring and credit building; and debt management services.

(d) Lead marketplaces and aggregators. Businesses that operate lead distribution platforms or marketplaces and that resell or route leads to businesses in the categories described in (b) and (c). Where we provide your information to such businesses, we require them by contract to handle it in accordance with applicable law.

(e) Service providers. Vendors that process information on our behalf, including website hosting and cloud infrastructure, CRM and lead-routing software, analytics and session-replay providers, communications providers (email, SMS, and telephony, including phone number verification services), advertising platforms, and professional advisors. Service providers are permitted to use your information only to provide services to us.

(f) Legal and safety disclosures. Courts, tribunals, regulators, law enforcement, and other parties where disclosure is required or permitted by law, including to comply with legal process, enforce our Terms of Use, protect our rights and property, or protect the safety of any person.

(g) Business transactions. A purchaser, investor, or successor in connection with a merger, acquisition, financing, reorganization, or sale of all or part of our business or assets, including during negotiations for such a transaction, subject to standard confidentiality protections.

One submission may result in multiple disclosures. Your information may be provided to more than one recipient in the categories above, and those recipients may each contact you. We maintain records of the recipients to which each submission is disclosed.

Third-party privacy policies apply. Once your information is disclosed or sold to an affiliate or Partner, that party's use of your information is governed by its own privacy policy. We encourage you to review the privacy policy of any business that contacts you.

6. Your Consent

Express consent at the point of submission. When you submit a form on our Website, you will be presented with consent language describing, and by submitting you expressly consent to: (i) the collection of the information in your submission; (ii) its use as described in this Privacy Policy; (iii) its disclosure, transfer, and sale to our affiliates and to Partners in the categories described in Section 5; and (iv) being contacted by us, our affiliates, and those Partners by telephone (including calls placed using automatic dialing systems and pre-recorded messages), SMS/MMS text message, and email at the contact points you provide, even if your number is on any do-not-call list, for purposes related to your inquiry and for offers of related products and services. Consent to be contacted is not a condition of any purchase.

Duration of consent. The consent you provide at the point of submission remains valid until you withdraw it, and is not limited to a single referral or transaction. Subject to Section 10 (Retention), your consent permits us to use, disclose, transfer, and sell your Personal Information — including to new affiliates and Partners — on an ongoing basis for the purposes described in this Privacy Policy, including re-contacting you and re-referring or re-selling your information where you have not completed a transaction or where new offers, Partners, or products may be relevant to you.

Implied consent for limited purposes. Where permitted by law, we rely on implied consent for purposes that a reasonable person would consider appropriate in the circumstances, such as responding to an inquiry you send us.

Withdrawal of consent. You may withdraw your consent to our collection, use, disclosure, or sale of your Personal Information at any time, subject to legal and contractual restrictions and reasonable notice, by contacting our Privacy Officer at privacy@autolendingcanada.ca. Please note:

• if you withdraw consent, we may be unable to provide our services to you;
• withdrawal is not retroactive: it does not affect disclosures already made before your withdrawal takes effect. If your information has already been provided to an affiliate or Partner, you may also need to contact that party directly to opt out of its communications, and we will, on request, tell you which parties received your information so you can do so;
• upon withdrawal, we will stop disclosing or selling your information to new recipients and will notify recipients to whom we disclosed your information within a reasonable period before your withdrawal, where required by law; and
• we may retain information as necessary to comply with law, maintain records of the consent you previously provided, and establish or defend legal claims.

7. Marketing Communications and Canada's Anti-Spam Legislation (CASL)

Where we send you commercial electronic messages (email or SMS/MMS), we do so in compliance with CASL, on the basis of your express consent, your implied consent (for example, because you made an inquiry with us), or another exemption under CASL.

Consent obtained on behalf of Partners. When you submit a form, we seek your consent to receive commercial electronic messages both on our own behalf and on behalf of our affiliates and Partners in the categories described in Section 5, whose specific identities may not be known at the time consent is obtained. In accordance with CASL:

• Auto Lending Canada is the party obtaining your consent, and you may withdraw that consent at any time by contacting us at privacy@autolendingcanada.ca;
• any affiliate or Partner that sends you a commercial electronic message in reliance on that consent is required to identify itself, provide an unsubscribe mechanism in each message, and honor your unsubscribe promptly; and
• if you withdraw the consent you gave through us, we will notify the parties to which we provided your information, and each such party is required to give effect to your withdrawal.

Unsubscribing. You can opt out of our marketing emails using the unsubscribe link in any email, opt out of our marketing texts by replying STOP, or contact us using the details below. We will process unsubscribe requests within the time required by law (no later than 10 business days). Even if you opt out of marketing, we may still send you non-commercial, transactional, or service messages related to an active inquiry where permitted by law.

8. Cookies, Tracking, and Advertising

We and third parties we work with use cookies, pixels, local storage, session storage, and similar technologies ("Cookies") to operate the Website, remember your progress and preferences, authenticate sessions, measure traffic and performance, record user-experience sessions, and deliver and measure advertising.

The third-party technologies used on our Website may include, without limitation: Google Analytics, Google Tag Manager, Google Ads conversion tracking, Meta (Facebook) pixel and Conversions API, and Microsoft Clarity. These providers may collect information about your visit (including pages viewed, actions taken, and identifiers such as IP address, cookie IDs, and advertising click IDs) and may combine it with other information they hold about you under their own privacy policies.

Advanced matching / server-side measurement. Where you submit a form, we may share hashed or unhashed identifiers (such as your email address, phone number, name, and postal code) with advertising platforms (for example, Google and Meta) to measure conversions, reduce duplicate reporting, and build audiences, in accordance with those platforms' terms and applicable law.

Your choices. Where required by law, we present a cookie consent banner allowing you to accept or refuse non-essential Cookies, and technologies that identify, locate, or profile you are activated only with your consent where the law so requires. You can also control Cookies through your browser settings and opt out of certain advertising cookies at youradchoices.ca. If you disable Cookies, some parts of the Website may not function properly.

9. Where Your Information Is Stored; Transfers Outside Canada

We store Personal Information in relational databases and CRM systems tied to your record. Information may be stored and processed in Canada and, through our service providers, affiliates, and Partners, outside of Canada (including in the United States). While outside Canada, information is subject to the laws of those jurisdictions, and governments, courts, law enforcement, and regulators there may be able to obtain access to it. By submitting your information, you consent to these transfers. Quebec residents: see Section 14.

10. Retention

We retain Personal Information for as long as reasonably necessary for the purposes described in this Privacy Policy and to meet our legal, regulatory, audit, and business requirements. Our standard retention schedule is as follows:

• Active use, disclosure, and sale. Unless you withdraw your consent earlier, we may use, disclose, transfer, and sell your Personal Information for the purposes described in this Privacy Policy for a period of up to seven (7) years from your most recent interaction with us (including a submission, communication, click, or response). Each new interaction restarts this period.
• Business and compliance records. We retain records of your submissions, the consents you provided, the consent language presented to you, the recipients to which your information was disclosed, and related transaction and compensation records for up to seven (7) years, or longer where required to comply with law or to establish, exercise, or defend legal claims.
• Decisions affecting you. Where we use Personal Information to make a decision that directly affects you, we retain it for at least one (1) year after using it, as required by BC PIPA.
• Destruction. When Personal Information is no longer required under this schedule, we securely destroy, erase, or anonymize it.

Anonymized or aggregated information that no longer identifies you may be retained and used without restriction.

11. How We Protect Personal Information

We protect Personal Information using administrative, physical, and technological safeguards appropriate to its sensitivity, including access controls limiting access to personnel who need it, encryption of data in transit, and contractual obligations on service providers. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. If a breach of security safeguards creates a real risk of significant harm to you, we will notify you and the appropriate regulators as required by law.

12. Your Rights: Access, Correction, and Complaints

Subject to applicable law, you have the right to:

• Access the Personal Information we hold about you, information about how it has been used, and the names or categories of the parties to which it has been disclosed;
• Correct Personal Information that is inaccurate or incomplete; and
• Complain about our handling of your Personal Information to our Privacy Officer and, if unresolved, to the applicable regulator: the Office of the Privacy Commissioner of Canada, the Office of the Information and Privacy Commissioner for British Columbia, the Office of the Information and Privacy Commissioner of Alberta, or the Commission d'accès à l'information du Québec.

To exercise these rights, contact our Privacy Officer using the details in Section 16 with sufficient detail to identify you and your request. We will respond within thirty (30) days or as otherwise required by law. Where the law permits a minimal fee for access, we will advise you of any fee before proceeding; access is free of charge for Quebec residents.

13. Age Restriction

Our Website is intended for individuals who are at least nineteen (19) years old and the age of majority in their jurisdiction. We do not knowingly collect Personal Information from anyone under 19. If we learn that we have collected such information, we will delete it. By using the Website, you confirm that you meet this age requirement.

14. Additional Disclosures for Quebec Residents

If you reside in Quebec, the following also applies:

• Person in charge of protection of personal information. Ryan Aghdam, our Privacy Officer, identified in Section 16, is the person in charge of the protection of personal information.
• Purposes and consent. We collect, use, and communicate your personal information for the purposes described in this Privacy Policy. Where we communicate your personal information to third parties for commercial purposes — including the sale of your information as described in Sections 2 and 5 — we do so only with your express consent, which is requested separately and in clear and simple language at the point of submission. You may refuse; refusing means we cannot provide you with our referral service.
• Communication outside Quebec. Your personal information may be communicated to recipients outside Quebec, including elsewhere in Canada and in the United States. Before doing so, we conduct the assessment required by law, taking into account the sensitivity of the information, the purposes of its use, the protections applied, and the legal framework of the receiving jurisdiction.
• Your rights. In addition to access and rectification, you may have the right to request the deindexation or cessation of dissemination of your personal information, to request that computerized personal information you provided be communicated in a structured, commonly used technological format (data portability), and to withdraw your consent at any time.
• Technology with tracking functions. Technologies allowing you to be identified, located, or profiled are activated only with your consent, which you may manage through our cookie consent tool.

15. Changes to This Privacy Policy

We may modify this Privacy Policy from time to time. The revised version will be posted on our Website with an updated effective date. For material changes, we will post a notice on our home page at least fourteen (14) calendar days before the change takes effect. Where a change involves a new purpose for the use or disclosure of Personal Information already collected, we will obtain any consent required by law. Your continued use of the Website after the effective date constitutes acceptance of the revised Privacy Policy.

16. How to Contact Us / Privacy Officer

Questions, requests, and complaints regarding this Privacy Policy or our handling of Personal Information should be directed to our Privacy Officer:

Privacy Officer: Ryan Aghdam Auto Lending Canada Ltd. 329 Howe St, Unit #768, Vancouver, BC V6C 3N2 Email: privacy@autolendingcanada.ca Phone: 1-844-405-5363

This Privacy Policy is dated and effective as of July 19, 2026.