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PRIVACY POLICY

Last Updated: September 12, 2024


British Columbia Automobile Association and our corporate affiliates (“BCAA”, “we”, “us”, or “our”) respect and uphold individual rights to privacy and the protection of personal information while balancing such rights with our need to process your personal information to manage our business and deliver our services to you. For clarity, our corporate affiliates that may process your personal information pursuant to this Privacy Policy include B.C.A.A. Holdings Ltd. and BCAA Insurance Corporation.

This Privacy Policy (the “Policy”) describes how we may collect, use, disclose, retain, dispose of and otherwise process (collectively, “process”), and how you may correct, update and access, your personal information that you provide as a user of, or that we collect through your use of, our websites, social media sites, mobile applications, products, services, software and tools (collectively, the “Services”), as well as through in-person and telephone exchanges. It does not apply to our employees’ personal information (except to the extent that they are users of Services in their personal capacity), business contact information, anonymized information or other information exempted from applicable privacy laws. For clarity, any reference to the “Services” includes a reference to any part or aspect of the Services.

Unless otherwise provided in an applicable Privacy Notice, this Policy references the BCAA Terms of Use and forms an integral part thereof. In the event of a conflict between the BCAA Privacy Policy and the Terms of Service, the Terms of Service will prevail. 

PLEASE READ THIS POLICY CAREFULLY. By using our Services, or otherwise by choosing to provide us with your personal information, you acknowledge and consent to us processing your personal information in accordance with this Policy and as may be further identified when the personal information is collected. If you do not consent to the processing of your personal information in accordance with this Policy, please do not access or continue to use any of our Services, or otherwise provide any personal information to us. 

PLEASE NOTE, the following Privacy Notices provide additional information about some of our Services:

  1. BCAA Privacy Notice
  2. BCAA Auto Marketplace Privacy Notice
  3. BCAA Connect Privacy Notice

4. Accountability

BCAA is responsible for your personal information under its control. We have appointed a Chief Privacy Officer who is accountable for BCAA's compliance with this Policy. The Chief Privacy Officer can be contacted at privacy@bcaa.com.

5. Personal Information

For the purposes of this Policy, “personal information” means any information about an identifiable individual or any information that can be used, either alone or in combination with other information, to identify an individual (for example, an individual’s name, mailing address, telephone number and email address), but excludes any information that is exempted by applicable privacy laws. For example, in Canada, personal information generally does not include any business contact information that is processed solely to communicate with that person about their employment or profession.

The types of information we receive and collect, and how we use or disclose that information, depends on how you interact with us, which of our Services you use, and how you use them. Certain of our Services have optional features which, if used, require us to collect additional information to provide such features. You will be notified of such collection, as appropriate. If you choose not to provide the information needed to use a feature, you will be unable to use the feature.

Directly Collected Personal Information

When you use our Services, we may collect the following personal information from you:

  • Contact information, such as first and last name, email address, mailing address and phone number;
  • Payment information, such as billing address and credit card information;
  • Unique identifiers, such as username, account number and password;
  • Identification, such as government issued identification documents and current photograph; and
  • Any other information you voluntarily provide through our Services.

Your personal information may be collected when:• You register for an account with one or more of our Services;

  • You submit an application for membership for one or more of our Services;
  • You make purchases through one or more of our Services;
  • You fill out free-form fields on our websites;
  • You connect with us through social media;
  • You connect with us through Customer Support channels;
  • You communicate with us by phone or email; and
  • You otherwise use our Services.

We only collect personal information that we need. We encourage you to not provide us with any personal information beyond what is necessary and as requested by us.

Automatically Collected Personal Information

We, and our third-party partners, may also automatically collect information about you and any computer or device you use to access our Services, read our emails or otherwise engage with us. Some of the information we may collect, and ways we may collect it include:

  • Cookies. When you visit or use our websites, we may send one or more cookies – small text files containing a string of alphanumeric characters – to your computer or device that allows us to uniquely identify your browser, computer or device. Cookies allow us to collect standard Internet log information about how and when you access and use our websites, including your IP address, unique device identifiers, location data, weblogs, time zone, date, your language preferences, browser settings and browsers used, web addresses visited, links clicked, other communication data, searches conducted and pages visited. We use cookies for a number of purposes, including to: ensure our websites are optimized for your use and for future communications between you and us; track your preferences you specify while using our websites; assist us to maintain and manage your status as logged in or logged out while you are using our websites; estimate and report our total audience size and traffic; and conduct research to improve our content, products and services. We may also use cookies and other technologies in online advertising campaigns to track responses to our ads. You can manage cookie preferences in your browser’s settings, but please note that if you refuse to ‎allow cookies, you may not be able to use certain features or functionality of our websites.
  • Log Files. We may record log file information each time you access our websites. This information may include information such as: your IP address; browser type; unique device identifiers; information about your computer or device; number of clicks; how you interact with links, features or functionality on our websites; and other such information.
  • Usage Data. We may also collect information about the way you use our Services. For example, the site from which you came and the site to which you are going when you leave our websites, the pages you visit, the links you click on, how frequently you access our websites, whether you open emails or click the links contained in emails, whether you access our websites from multiple devices, last login time, and other actions you take on our websites. We may collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for our websites.

  • Google Analytics. We use Google Analytics to help us analyze how visitors use our website. Google Analytics uses ‎cookies and similar technologies to collect and analyze information about use of our Services and to ‎report on activities and trends. Google Analytics may also collect information regarding the use of ‎other wesbsites, apps and online resources. You can learn about Google’s practices by going to ‎https://www.google.com/policies/privacy/partners‎, and opt out by downloading the Google Analytics ‎opt-out browser add-on available at https://tools.google.com/dlpage/gaoptout.‎

Collection from Third Parties

We do not knowingly collect your personal information from a third party, unless you consent or we are otherwise exempted, authorized or required by applicable laws to do so. For example, we may collect your personal information from third parties as follows:

  • Your authorized representative(s);
  • Organization(s) that you previously provided consent to in respect of their collection of your personal information; or
  • Public sources in which your personal information is publicly available.

If we collect your personal information from a third party, we will only process that information for the specific purpose for which it was provided to us in accordance with this Policy (and an applicable Privacy Notice) and the policy under which that information was collected.

Communication between users

Certain of our Services may facilitate communication between users but we do not assume responsibility ‎for the use of content or information exchanged during these interactions. We encourage you to exercise ‎caution when disclosing information to other users. You are solely responsible for the personal ‎information you share through our Services and we do not guarantee the privacy or security of the ‎information you share with other users.‎

Links to Other Sites

Our Website may contain links to other websites, applications or Internet resources (“Third-Party Services”) which are provided or made available solely for your convenience and information. When you click on one of those links you are contacting those Third-Party Services. We do not endorse and have no responsibility or liability for, nor do we have any control over, those Third-Party Services, their content or their processing of your personal information. We encourage you to read the privacy policies of those Third-Party Services to learn how they process your personal information.

Information about Children

We understand the importance of protecting children’s privacy. Our Services are not directed at children under the age of 13 and we do not knowingly collect personal information from children under the age of 13 without parental consent, except as permitted by applicable law.

We may collect personal information about children under the age of 13 from their parent or legal guardian. By providing such information, you confirm that you are the parent or legal guardian of any such children. If you register any children under the age of 13 on your BCAA membership, you are hereby deemed to consent to our use, collection and disclosure of such children’s personal information strictly for the purposes of providing Services.

If you believe that a child under the age of 13 has provided us with personal information without parental consent, please contact us at the address indicated in Section 11 below and we will work to delete that data from our systems.

6. Purpose for Which Personal Information is Processed

Generally, we may process your personal information for the following purposes:

  • To verify and authenticate your identity;
  • To contact you for mailing and renewal purposes;
  • To operate, maintain and provide to you the Services and all features and functionality of our websites and mobile applications;
  • To contact you with respect to your purchases or transactions;
  • To deliver products and fulfill requests;
  • To maintain accurate records;
  • To ensure that the Services are optimized for your use and benefit;
  • To analyze user experience and improve the Services;
  • To provide you with requested information, process your questions and/or answer your queries;
  • To communicate with you to provide you with information about us (including news releases, newsletters and notices regarding upcoming promotions or events);
  • To solicit feedback from you about your satisfaction and experience with our Services (including through occasional surveys);
  • To communicate with you to provide you services, contacts, materials and/or recommendations for your needs as identified by you through phone, email or our websites;
  • To carry out our obligations arising from any contracts or transactions entered into between you and us;
  • To comply with internal policies and procedures, applicable laws, regulations, subpoenas, court orders and other legal, accounting or security requirements; 
  • To protect us, yourself and others from fraud and error, and to safeguard our business interests; 
  • To collect debts owed to us; 
  • To manage or transfer our assets or liabilities (for example, in the case of an acquisition or merger, the provision of security for a credit facility or the change of a supplier of products or services); and
  • To share your personal information with our employees, contractors, consultants and other third party service providers including, but not limited, to website hosting providers, advertising agencies, payment processors or customer service agencies (“Service Providers”) who require this information to assist us with establishing, maintaining and managing our relationship with you and optimizing and providing the Services for your use and benefit. Please note that we may change or add Service Providers at any time, in our sole discretion, either in Canada or elsewhere. We encourage you to reference this Policy (and any Privacy Notices applicable to the Services you are using) from time-to-time to obtain updated information.

We will not process your personal information for other purposes without your consent, except where authorized or required by law.

7. Disclosure of Your Personal Information

We will not share your personal information with any third party, except as indicated in this Policy (or an applicable Privacy Notice) or as authorized or required by law.

We may disclose your personal information for the purposes as described in this Policy (and any applicable Privacy Notices) in the following ways: 

  • To our employees, contractors and agents on an as-needed basis;
  • To our affiliates and business partners;
  • To our Service Providers (as discussed above);
  • To law enforcement, government or regulatory bodies, or other lawful authorities, as strictly required by law; and
  • To third parties, in accordance with applicable law, in connection with a corporate reorganization, a merger or amalgamation with another entity, or a sale of all or a substantial portion of our assets or securities, provided that the disclosed information continues to be used solely for the purposes permitted by this Policy (and any applicable Privacy Notices) by the entity acquiring the information.

Our Service Providers, may be located outside of Canada, and you acknowledge that personal information may be processed and stored in foreign jurisdictions with different (and perhaps weaker) privacy laws, and that the governments, courts or law enforcement or regulatory agencies in those jurisdictions may be able to obtain disclosure of that personal information through the laws of the foreign jurisdiction.

8. Legal Basis for Processing Your Personal Information

We will process your personal information only with your knowledge and consent, except where exempted, authorized or required by applicable laws. The form of consent may vary depending on the circumstances and the type of information being requested. Your consent may be express, with clear options to say “yes” or “no” (such as by being asked to check a box to indicate your consent), or implied ( such as when you provide us with your address through a form or email seeking information and we use those means to respond to your request). Your consent can also be provided by your authorized representative. Taking into account the sensitivity of your personal information, purposes of collection, and your reasonable expectations, we will obtain the form of consent that is appropriate to the personal information being processed. 

When we process your personal information for a new purpose, we will document that new purpose and ask for your consent again.
You may refuse to provide consent or may notify us at any time that you wish to withdraw or change your consent to the processing of your personal information without penalty, subject to legal, contractual or other restrictions and reasonable notice, by opting out of the use of your personal information by contacting our Chief Privacy Officer (see Section 11 below). However, if you withdraw or change your consent, we may not be able to provide you with the Services.

Aside from consent, we may also process your personal information under other legal bases, as permitted by applicable laws

9. Security of Personal Information 

The security of your personal information is important to us. We protect the personal information in our custody or under our control using reasonable physical, technological and organizational safeguards designed to prevent unauthorized access, collection, use, disclosure, copying, modification, destruction or similar risks.

We will take reasonable measures, through contractual or other reasonable means, to ensure that our Service Providers implement a comparable level of protection. Each of our employees is responsible for maintaining the confidentiality of all personal information to which they have access. We keep our employees informed about our policies and procedures for protecting personal information.

However, no method of transmission over the Internet, or method of electronic storage, is completely secure. As such, despite our safeguards and protocols, we cannot fully guarantee the security of your personal information and you should always exercise caution when disclosing personal information over the Internet.

10. Privacy Rights and Choices

Accessing Your Personal Information

You have a right to access your personal information that we hold. 

Upon your written request, we will provide you your personal information in our possession or under our control. We will also provide your information about the ways in which that information is being used and a description of the individuals or organizations to whom that information has been disclosed. We may charge you a reasonable fee for doing so.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who does not have a right to receive it.

Access may be declined where authorized or required by applicable law. If access cannot be provided, we will notify the individual making the request within 30 days, in writing, of the reasons for the refusal.

We will make our policies and practices relating to the management of your personal information readily available to you.

Correcting Your Personal Information

We will make a reasonable effort to ensure that personal information we are using or disclosing is accurate, complete and up-to-date and reasonably necessary for the purposes for which it is to be used.

If you demonstrate the inaccuracy or incompleteness of personal information, we will amend the information as required. If appropriate, we will send the amended information to third parties to whom the information has been disclosed.

If a challenge regarding the accuracy of personal information is not resolved to your satisfaction, we will annotate the personal information in our possession or under our control with a note that the correction was requested but not made.

11. Retention of Your Personal Information

We will delete, destroy, erase, aggregate or make anonymous documents or other records containing personal information as soon as it is reasonable to assume that the original purpose is no longer being served by retention of the information and retention is no longer required for a legal or business purpose.

We will keep personal information used to make a decision affecting you for at least one year after using it to make the decision.

12. CASL Policy

We are committed to compliance with Canada’s Anti-Spam Legislation (“CASL”). Any electronic ‎communication we send to outside parties is protected by a range of business procedures, processes ‎and policies to ensure that such communication is done in compliance with CASL. In our electronic ‎communications with outside parties, we comply with the rules established by CASL and enforced by ‎various Canadian authorities including the Canadian Radio-television and Telecommunications ‎Commission. CASL regulates, and our policies generally apply to, each commercial electronic message ‎‎(a “CEM”) that we send. A CEM is an electronic message sent to an electronic address that, among its ‎purposes, encourages participation in a commercial activity.‎

In addition to adopting and updating this Policy, we undertake various transparency initiatives to ensure ‎we comply with CASL, which include:‎

  • Consent.  We do not send you CEMs without your consent. This consent typically must be “express” ‎‎(i.e. expressly acknowledged by you), but in certain circumstances can be “implied”. In other ‎limited circumstances, consent is not required. We have modified or adopted our sign-up, ‎registration and consent forms in order to ensure that your consent is meaningful (i.e. informed ‎and freely given) as required by CASL. When we collect your electronic contact information, you ‎will know the exact purposes behind the collection.‎
  • Content.  We have adopted processes to ensure that our CEMs contain the following requirements ‎prescribed under CASL, which will usually be in the footer of the CEM. We will:
    ‎
    • identify ourselves as the party sending the CEM, and whether we are sending the message ‎on our own behalf or on behalf of someone else;
    • provide you with our contact information; and
    • set out a clear, working unsubscribe mechanism or preference centre that is easy to use, ‎automatic, and at no cost to you (other than your own cost of connecting to the Internet).‎
  • Clarity.  We ensure that each aspect of a CEM (including its header, content, or any links or URLs in ‎the CEM) conveys the appropriate information, whether viewed individually or taken as a whole, ‎so that you always know what you are clicking on.‎

If you receive a CEM from us but believe that you should not have or no longer wish to receive CEMs, ‎we will aim to respect your preferences in a timely manner once you update them through our ‎unsubscribe mechanism. CASL requires us to process unsubscribe requests within 10 business days. If ‎you have any questions or concerns about our unsubscribe mechanisms, you may contact using the contact information provided in Section 14 below.

13. Updates or Changes to this Policy

This Policy was last updated as of the “Last updated” date set out at the beginning of this Policy. 

We may update this Policy time to time to ensure ongoing compliance with applicable laws and for any other purpose that we deem reasonably necessary. We therefore encourage you to periodically review this Policy to ensure you are aware of any changes.

If we make any material changes we will either (a) notify you by email (sent to the email address listed in our records), or (b) provide a notice on our websites or through our mobile applications before the change becomes effective. Any change to this Policy will apply to existing information, as well as information collected after the date that this Policy is posted or on the date as specified in the notification. Your continued use of the Services following the effective date of any changes to this Policy signifies your acceptance of such changes.

14. Contact Information for Chief Privacy Officer

If you have any questions or concerns regarding our compliance with this Policy and our processing of your personal information, you may contact our Chief Privacy Officer at privacy@bcaa.com.

If you are not satisfied with our Chief Privacy Officer’s response to your question or concern, you may be able to file a complaint under applicable privacy laws. Our Chief Privacy Officer will provide you with the contact information to do so if requested.

15. California Residents

If you are a California resident, do not enter your personal information through this site or other electronic means. You may inquire about our services through our call centre at 1.888.268.2222.

BCAA does not sell or rent any personal information. 

BCAA PRIVACY NOTICE

In addition to the BCAA Privacy Policy, this Privacy Notice also applies to users of, or visitors to, BCAA’s website operated at www.bcaa.com and other locations from time to time, social media sites and mobile applications (collectively, the “Site”). Terms used but not defined in this Privacy Notice have the meanings given to them in the BCAA Privacy Policy.
Information we collect

When you use the Site, or the Services we provide through the Site, or interact with us via telephone or in person, we may collect the following additional information

  • Your driver’s license and driving record;
  • Your vehicle information;
  • Information obtained during the course of dispatching a service vehicle, including the type of service required and the tow destination;
  • Information related to insurance, including driving records, medical history, claims history, information on dependents, insured residence particulars or next of kin particular;
  • Your travel needs, including such items as travel arrangements and medical or dietary restrictions for travelers;
  • Your payment information;
  • Your credit information, in order to permit us to perform credit checks;
  • Information that is linked to your BCAA account; and
  • Your products and services history at BCAA.
Your information may be collected when:
  • You submit an on-line application for membership or purchase of insurance through the Site.

We may collect information from the following third-party sources, provided you have consented to such collection or we are otherwise exempted, required or permitted by applicable law to do so:

  • the Canadian Automobile Association (CAA), of which BCAA is a member, and the American Automobile Association, with which BCAA is affiliated (with respect to members requiring products, services or insurance coverage in other jurisdictions);
  • underwriters, agents, brokers and reinsurers, as appropriate (with respect to insurance coverage or claims);
  • other insurers or credit reporting agencies, as appropriate given the product or service in question (with respect to driving records and credit information); and
  • lawyers, private investigators and other third parties (with respect to investigating, evaluating and adjusting claims).

Additional purposes for which personal information is processed

We may process your personal information for the following additional purposes:

  • To provide you with the products and services requested;
  • To contact you for mailing and renewal purposes;
  • To contact you to advise you of any existing services and benefits that may be of interest to you, including via direct marketing, in accordance with applicable anti-spam laws;
  • To promote products and services with member companies of BCAA;
  • To coordinate and liaise with other CAA and AAA clubs as is appropriate in the circumstances;
  • To meet legal or statutory requirements or obligations to investigate fraud or other potential criminal activity;
  • To ensure coordination of dispatch for members needing assistance by the use of external services such as Google Maps Coordinates Software;
  • To process, investigate and administer claims and assessments of losses in the event of a claim;
  • To allow the establishment of the risk premium associated with an insurance policy;
  • To underwrite and price your policy application and any subsequent policy changes or renewals; and
  • To analyze business results, compile statistics, perform administrative tasks such as accounting and information system activities, and conduct marketing activities and underwriting research and modeling;
  • To develop personalized experiences and services and proactively offer those experiences and services to you;
  • To train our agents, including virtual agents, and for compliance purposes; and
  • To protect the personal safety of our employees, our client or third parties.
Additional ways we share your personal information
BCAA may disclose your personal information for the purposes described in the Privacy Notice in the following ways:
  • To hotel, airline, rental car and/or other travel suppliers whose products or services you have purchased, including to confirm your reservation and travel preferences.

California Residents

If you are a California resident, do not enter your personal information through this site or other electronic means. You may inquire about our services through our call centre at 1.888.268.2222.

BCAA does not sell or rent any personal information. 

BCAA AUTO MARKETPLACE PRIVACY NOTICE

In addition to the BCAA Privacy Policy, this Privacy Notice also applies to users of the website operated at https://marketplace.bcaa.com and other locations from time to time, and the platform, products, services, software and tools we provide through such websites (the “Auto Marketplace”). Terms used but not defined in this Privacy Notice have the meanings given to them in the BCAA Privacy Policy.

Additional information we collect

When you use the Auto Marketplace, personal information may be collected when you interact with other users on the platform.

Additional ways we share your personal information

When you use the Auto Marketplace, we may disclose your personal information for the following additional purposes:

  • To other users of the Auto Marketplace in order to facilitate communication between sellers and buyers of vehicles.

We may also disclose your personal information for the purposes described in the BCAA Privacy Policy and this Privacy Notice to our Service Providers, such as ID verification service providers and vehicle history report providers.

Our Service Providers, may be located outside of Canada, and you acknowledge that your personal information may be processed and stored in foreign jurisdictions with different (and perhaps weaker) privacy laws (including but not limited to the United States and Singapore), and that the governments, courts or law enforcement or regulatory agencies in those jurisdictions may be able to obtain disclosure of that personal information through the laws of the foreign jurisdiction.

Auto Marketplace may contain features that enable you communicate with and request services from third parties. We do not endorse and have no responsibility or liability for, nor do we have any control over, those third parties, their products or services, or their processing of your personal information. We encourage you to read the privacy policies of those third parties to learn how they process your personal information.

BCAA CONNECT PRIVACY NOTICE

In addition to the BCAA Privacy Policy, this Privacy Notice also applies to users of the website operated at https://connect.bcaa.com and other locations from time to time, and the platform, products, services, software and tools we provide through such websites (“BCAA Connect”). Terms used but not defined in this Privacy Notice have the meanings given to them in the BCAA Privacy Policy.

Additional information we collect

When you use BCAA Connect, personal information may be collected when you interact with other users on the platform.

Additional ways we share your personal information

When you use Connect, we may disclose your personal information to visitors and users of the Connect platform.

Our Service Providers, may be located outside of Canada, and you acknowledge that your personal information may be processed and stored in foreign jurisdictions with different (and perhaps weaker) privacy laws (including but not limited to the United States), and that the governments, courts or law enforcement or regulatory agencies in those jurisdictions may be able to obtain disclosure of that personal information through the laws of the foreign jurisdiction.