Privacy Policy

  1. Introduction Inc. (“We”, “Our”, “Us”) is an automotive technology company committed to providing the best possible web experience and software products primarily focused on offering credit and financial services for automotive customers through partnerships with Canadian automotive dealerships (“Dealership Partners”). Because We respect the right to privacy, We have developed this Privacy Policy (“Privacy Policy”) to inform web visitors, customers, and users of our software products (“You”, “Your”) about Our privacy practices regarding the data collected in relation to the use of Our website, located at (the “Website”) and various software products and services, such as AVA ID™, AVA Credit™, AVA Trade™, AVA Buy™, etc. (the “Services”). These Services may be used to directly or indirectly distinguish, identify, or contact a specific individual (“Personal Information”). We may collect and store Personal Information in order to provide access to and use of the Services.

  1. Scope of This Privacy Policy

In keeping with our commitment to Your privacy, this Privacy Policy will apply to:

  • The type of information We collect, use, and disclose;
  • How the information We gather is used and to whom it is disclosed;
  • Your ability to opt-out of future notifications and withdraw consent;
  • Security procedures We have put in place to protect Your information from loss, misuse, or alteration

  1. Our Commitment to Privacy

We recognize the importance of privacy and are committed to protecting the privacy of all of those who use Our services. This Privacy Policy sets out our practices regarding the collection, use and disclosure of Personal Information in connection with the Website and the Services. If You are using the Website or the Services, You may be asked to provide Personal Information. Please note that We are asking for this information for the limited purposes as defined in this Privacy Policy. By using Our Website or Services, You consent to Our collection use and disclosure of Your Personal Information in accordance with the terms of this Privacy Policy. We do not sell the information You provide to any third party without Your consent.

  1. Application

This Privacy Policy applies to all information We collect for the purpose of providing access to and use of the Website and the Services. Our Services may require the involvement of one or more partners, including Dealership Partners and trusted third parties required to facilitate the provision of the Website and the Services. Each of Our partners maintains its own privacy policy that may be viewed on their respective websites. We strive to provide the highest level of privacy possible, and therefore require that our partners offer no less protection than that offered in this Privacy Policy and as otherwise required by law. In addition, each of our partners must meet the data protection requirements of Canadian and other relevant national laws.

  1. Information We Collect From You

  1. How We Collect Information from You

We collect information from You when You interact with the Services through:

  • Our Dealership Partners. You may be asked to provide Our Dealership Partners with information to be disclosed to Us in connection with the Services. This information may be used by Us to provide the Dealership Partner with identity verification and other reporting about You related to the Services.
  • A Direct Link. In some instances, You may be asked to upload Your information to Us directly or indirectly through a trusted third party via a direct link. This information may include uploading a driver’s license, biometric selfie or providing photo identification for the purpose of identity verification.
  • Communicating with Us. You may disclose information to Us via direct email or verbal communication in connection with the Services.
  • Visiting the Website. When You visit the Website, We may collect non-identifiable information about Your visit. 

  1. Personal Information

We may collect Personal Information from You that You voluntarily submit to Us, including information that You provide when engaging with any of our Services. We do not collect any Personal Information from a visitor to Our Website unless that visitor explicitly and intentionally consents to providing it. Under no circumstances do We collect any sensitive personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, or sexual orientation. If You are simply browsing our site, We do not gather any personal information about You. We do not collect Personal Information from individuals under the age of 16.

Personal Information will only be collected for specific identified purposes and consented to at the time of collection or as otherwise outlined in this Privacy Policy.

  1. Purposes for Which We Collect and Use Your Information

  1. Facilitating the Use of Our Services: When you interact with the Services through a Dealership Partner, We may collect Personal Information for the purpose of verifying Your identity or to generate a report related to the Services. We use this information to operate, maintain, and provide You with the features and functionality of Our Services. We may receive information about You from third parties, including Our Dealership Partners when they provide us with information about You. We may also collect information about You that is publicly available on behalf of Our Dealership Partners.

The provision of Our Services may require the collection, use, and storage of your information in association with a trusted third-party with Your consent. In some cases, a trusted third-party that is required for the performance of Our Services may use or store Personal Information outside of Canada. Personal Information stored outside Canada may be subject to different laws than those in Canada and may be accessible to law enforcement agencies outside of Canada where permitted by law. Although we take all commercially reasonable efforts to ensure trusted third parties safeguard info, including Our Dealership Partners, we do not exercise control over such entities. We recommend that you review all applicable privacy policies and terms of use of these third parties prior to disclosing Your Personal Information.

AlthoughYou may disclose Personal Information to Our Dealership Partners, for the purpose of generating  identity verification results and other related reporting in connection with the Services, We are not responsible for the sites and services provided by our Dealership Partners. We recommend that You review their applicable privacy policies prior to disclosing any Personal Information to these entities.

  1. Communicating with You: We may use the information that You disclose to Us to communicate directly to You to respond to any inquiries (e.g., support requests or account verification) or service-related emails (e.g., technical and security notices). This communication is necessary for our legitimate interests, namely administering the Services and communicating with You in relation to the Services. We will only process Your Personal Information in this manner to the extent that You have given Us consent to do so and will only communicate with You in accordance with applicable anti-SPAM legislation.

  1. Payment processing, Hosting and Related Services: Third-party vendors and other service providers may be required for one or more of Our Services, including web hosting, payment processing, email, phone, and other risk service providers. If payments are processed through a  credit card or electronic funds transfer, We may provide Your Personal Information, including credit card details to appropriate financial institutions, processors, and third parties under contract with Us for providing payment. In each case, the distribution of Your Personal Information will be used by such an entity for its internal use related to fulfilling the transaction services for Us, will be treated as confidential by this entity, and will be transferred between Us and this entity only via encrypted means. Please note, that this information is only used to facilitate transactions. We may store credit card information for the purpose of a subscription. This credit card information is encrypted and accessible only by means of a secure link. Credit card information is deleted from our system as soon as it is no longer required (e.g., termination of services).

  1. Consent to the Collection of Personal Information

We use Your personal information only with Your meaningful legal consent, except as otherwise permitted or required by law. The consent provided for the use of Personal Information is for the specified, explicit, and legitimate purposes as outlined in this Privacy Policy, and/or as otherwise specified prior to Your providing express consent. You may withdraw Your consent to the use of Your Personal Information by contacting Our privacy officer by emailing When We collect information from You, You will be given the opportunity to opt-out of receiving further information from Us or any associated third party. We will explain the consequences if You decide to withdraw Your consent for Us to use Your personal information. Any request to withdraw consent will be processed within the legally required time periods.

You may explicitly and intentionally provide Us with, and consent to, Our collection of certain Personal Information by:

  1. E-Mail Request for Information: We use links throughout our site to provide You with the opportunity to contact Us via e-mail to ask questions, request information and demo materials, or provide comments and suggestions. You may also be offered the opportunity to have one of Our representatives contact you personally to provide information about Our Services. To do so, We may request additional Personal Information from You, such as Your name, email address, and/or telephone number, to help Us satisfy your request.

  1. Registration and Use of Services: If you choose to register for and/or use one of the Services, We will request certain information from You. Depending on the type of Service that You request, You may be asked to provide different Personal Information. For certain Services, We may require Your name, address, telephone number, e-mail address, date of birth, gender information, photograph or other appearance information for biometric authentication, and driver’s license photo and/or number. Other Services may require different or supplemental information from You in order to deliver a particular Service. 

By corresponding with Us, registering for or otherwise using the Services, You consent to Our collection, use, and disclosure of Your Personal Information in accordance with the terms of this Privacy Policy.

  1. New Consent Required

In the event that Personal Information is required for a new purpose, We will disclose the new purpose and request consent to collect Personal Information.

  1. No Consent Provided

Although not legally required to provide Personal Information, We reserve the right to withhold or deny Services where the appropriate Personal Information is not provided to carry out the associated purpose.

  1. Withdrawal of Consent

You can withdraw Your consent to the collection, use, and disclosure of Your Personal Information at any time by contacting Us and informing Our Privacy Officer by emailing

  1. Disclosure without Consent

We will only disclose Your information without consent to third parties, government authorities, or law enforcement to the extent that We are permitted or required to do so by law.

  1. Accuracy of Collected Information

We implement policies and procedures to ensure that the Personal Information in Our possession is accurate, complete, and up-to-date. You can submit updates to Your Personal Information to Our Privacy Officer at any time. Any changes to Personal Information in Our possession that are used by third parties or Our partners will also be updated of any new changes.

  1. Access to Personal Information

An individual may request access to the Personal Information that We hold about themselves at any time. We will respond to requests for access promptly and within the legally mandated time frame subject to any refusals permitted or required by law. Any refusals to grant access will be accompanied by associated reasons and information regarding available recourse. Requests for access to Personal Information can be directed to Our Privacy Officer via email to

  1. Retention of Personal Information

We retain Personal Information only for as long as needed to perform the purposes identified in this Privacy Policy. Once Personal Information is no longer required for the purpose for which it was collected, We will apply all commercially reasonable safeguards to safely and securely destroy said Personal Information.

  1. Website

We provide public access to information regarding the Services via the Website.

14.1 Statistical Information About Your Visit: When You visit Our Website, Our computers may automatically collect statistics about Your visit. This information does not identify You personally, but rather provides Us with information about Your visit to Our Website. We may monitor statistics such as how many people visit our site, the user's IP address, which pages people visit, from which domains our visitors come, and which browsers people use. We use these statistics about Your visit only to help Us improve the performance of the Website.

14.2 Use of Cookies: We only use "cookies" as described in this section. A "cookie" is a piece of information that our Website sends to Your browser, which then stores this information on Your system. Cookies are required to provide access Our Website. When Your browser window is closed; however, the cookie is automatically deleted from Your system. You should be aware that cookies contain no more information than You volunteer, and they are not able to access Your hard drive and return to the sender any personal or other information from Your computer.

You have the option to restrict or deny the use of cookies on the Website through Your browser settings; however, this may result in the inability to access or otherwise interfere with the use of the Website.

14.3 Linked Third Party Websites: The Website may contain links to third party sites. We are not responsible for the privacy practices, privacy statements, acceptable use policies, or any other content regarding these other sites. We strongly recommend that You read the privacy policies and terms and conditions of use of any third party to understand how they collect, use, and share information.

  1. Opting Out of Future Notifications

From time-to-time, We may notify You of new products, announcements, upgrades, and updates. If You would like to opt-out of being notified, please contact Us via email at

  1. Security Procedures and Safeguards

We consider the protection of all data and Personal Information We receive from You as critical to Our corporate mission. Please be assured that We have security measures in place to protect against the loss, misuse, and alteration of any information We receive from You in accordance with applicable law.

16.1 Procedural Safeguards: We maintain physical, electrical, and procedural safeguards in connection with the collection, disclosure, storage, use, and deletion of Personal Information. Proof of identity may be required upon request to disclose Personal Information to You. You should protect against the theft of Your Personal Information through safeguarding Your passwords and devices.

16.2 Technological Safeguards: As with any transmission over the Internet, there is always some element of risk involved in sending Personal Information. To try and minimize this risk, We encrypt all information that You submit in relation to Our Services. Our Website uses the Secure Sockets Layer (SSL) protocol. We use Amazon Web Services (AWS) to store Your data, which is encrypted both in transit and at rest.

16.3 Personnel Safeguards: Our employees who have access to Personal Information receive privacy training and are required to respect the confidentiality of such information pursuant to their employment agreement with Us. Restrictions to access to Personal Information at the personnel level include restricted access to physical locations in which Personal Information is held, as well as technological protections (e.g., passwords). Disclosure and access to Personal information by personnel is limited to the extent required to reasonably fulfill the specific purposes for which it was provided.

  1. Notification of a Security Breach

In the event of a security breach of the abovementioned safeguards involving Personal Information in Our control presents a real risk of significant harm, notice of the breach will be provided without undue delay to the affected individual(s).

  1. Changes to this Privacy Policy

We may revise or update this Privacy Policy from time to time. If a material change is made to this Privacy Policy and/or the way We use Your Personal Information or other data, We will post prominent notice of the nature of such changes on the first page of this policy.

  1. Inquiries Regarding This Privacy Policy

Questions, complaints, or requests for further information regarding this Privacy Policy or Our practices related to the collection of Personal Information should be directed to the Privacy Officer at Please specify "Privacy Policy" in the subject line of Your email. All complaints We receive related to Personal Information are investigated.

This Privacy Policy was last modified on October 21, 2022.