This Privacy Policy describes the policy of SparkLease Inc., located at #405-200 Consumers Rd, North York, ON M2J 4R4 ("SparkLease" or "we" or "us"), regarding the collection, use, storage, sharing and protection of your personal information ("Privacy Policy"). This Privacy Policy applies to the www.sparklease.com site, services, applications and tools (collectively, the "Services") regardless of how you access the Services, including access through mobile devices and mobile apps.

SparkLease has a practice of protecting the privacy and security of customer, supplier and employee records. We are committed to meeting our obligations under Canadian data privacy laws, including the Personal Information Protection and Electronic Documents Act, S.C. 2000, c. 5, and applicable provincial laws. We adhere to the privacy principles set out below, which govern the way we collect, use, store and disclose personal information that is obtained in the course of development, sales, promotion and distribution of our products or in the course of employment.

By using SparkLease and related Services, you give explicit consent to SparkLease for the collection, use, disclosure and retention of your personal information by us, as described in this Privacy Policy and our Terms of Use.

SparkLease may change this Privacy Policy from time to time. We will give notice of amendments as described in our Terms of Use.

SparkLease and related Services are accessible through sparklease.com without registering for an account. We collect minimal information that can be used to identify you by default.

Information that we collect automatically when using SparkLease, our Services and/or reply to ads or other content using SparkLease, we automatically collect certain information sent to us by your computer, mobile device or other equipment that you use to do this. This information includes, but is not limited to:

• information from your interaction with SparkLease and the Services, including, but not limited to, device ID, device type, geo-location information, computer and connection information, statistics on page views, traffic to and from SparkLease, referring URL, ad data, IP address and standard web log information; and
• information we collect through cookies, web beacons and similar technologies.

For information that is provided to us, we collect your information from the following sources:

• information you give us when you fill out forms, such as during account registration, customer service inquiries, online purchases, and surveys;
• information from your interaction with SparkLease and the Services, including, but not limited to, device ID, device type, geo-location information, computer and connection information, statistics on page views, traffic to and from SparkLease, referring URL, ad data, IP address and standard web log information;
• information that we collect automatically when you visit our website, such as information about your browser settings and other information collected through cookies;
• information that you provide to us when you register for an Account or use the Services (your name, your address, your telephone number, your email address, your driver license, your Social Insurance Number ("SIN"), and your credit information;
• additional information that you may provide to us through social media sites or third-party services;
• information provided in the context of dispute resolution, correspondence through SparkLease or correspondence that is sent to us; and
• your vehicle sales contract if you choose to submit it to us for information verification.

We may receive or collect additional information about you from third parties and add this to our account information. This information includes, but is not limited to demographic data, navigation data, additional contact data and additional data about you from other sources, such as public authorities, to the extent permitted by law.

We use your information to provide products and services and to manage our business operations. We may use your information in order to fill your orders, answer your inquiries, authenticate you when you sign into online services, prevent loss and fraud, and analyze our business operations and website performance.

We use your information for marketing and promotional purposes, including with our promotional partners.

We combine all the information we collect, other than information relating to your browsing history, in order to:

• provide you access to our Services, including creating and displaying to you advertisements and listings posted on SparkLease;
• to provide values and/or offers for cars that you would like to sell or trade in;
• to prevent, detect and investigate potentially prohibited or illegal activities, fraud and security breaches and to enforce our Terms of Use;
• to perform data analysis, including market and consumer research, trend analysis, demographic analysis, and financial analysis;
• to personalize, measure and improve our Services, content and advertisements;
• to contact you, by e-mail, push notification, text message (SMS), by telephone or by other electronic means, to inquire about our Services for the purpose of targeted marketing activities, updates, and promotional offers based on your message preferences;
• to provide you with other services that you have requested, as described when we collected the information;
• to comply with applicable legal requirements and policies;
• apply for credit with a dealer or one of our finance partners;
• to create listings and advertisements for any cars and other vehicles that you list for sale with us.

We may disclose your Personal Information to lenders, credit bureaus, employees, contractors and consultants. Personal Information also be disclosed to other third-party agents or service providers ("Third Parties") who require this information to help us establish, maintain and manage our business relationship to you, or to Third Parties you have provided your consent to receive information about financial products or services that may be of interest to you.

We share information with Third Parties who may be outside of Canada and may be subject to laws that are different from those in Canada. These Third Parties may combine the information we provide with other information that they have collected from you.

We use Third Parties to assist us in our operations, including our direct advertising and marketing services. We may also share your information with these third parties in order to provide services to you.

We may offer sign-on Services that enable you to use SparkLease or related websites with your third-party social media website login credentials, such as Facebook, Google Plus, Twitter, Instagram, and WeChat.

SparkLease has no control over the privacy policy of Third Parties that may apply to you. When we work with third parties or use third-party tools to provide certain services, we will explicitly indicate which privacy policy applies to you.

In the normal operation of the Services users may choose to disclose their personal information to other users. In particular, our Service allows users to share advertisements and other information with other users, thereby making this shared information accessible to other users.

Since SparkLease also enables you to directly contact a buyer or seller, we recommend that you consider how you share your personal information with others. You are solely responsible for the personal information you share through SparkLease and therefore we cannot guarantee the privacy or security of the information shared by you with other persons.

We may use credit card and other personally identifiable information (such as PayPal email addresses) you submit to us, and other information that we collect, as required, to process payments you make through the Site through our third-party payment processors. We do not store credit card or other payment method information. We may also share personally identifiable information with our third-party payment processors for risk management and fraud prevention.

If you apply for credit on the Sites with our dealers and lenders or any third party, you will need to provide your Personal Information, including your address, credit information, employment, and other financial information. We may share your application information with the dealership(s) you selected and our lenders/financial partners so that they can process your application.

If we sell all or substantially sell all of our business or sell or transfer all or a material part of our assets or are otherwise involved in a merger or transfer of all or a substantial part of our business, we may transfer all your Personal Information that we have collected and stored, to the party or parties involved in the transaction. We will require such providers to maintain your Personal Information confidentiality, to use it only for the purposes of the transaction and to safely destroy it once the transaction fails or when its purpose is fulfilled.

Personal Information and Data Technologies may be shared with lenders, dealers and manufacturers, and their agents and third-party service providers, who will use that Information in accordance with their own privacy policies.

From time to time, we may offer you opportunities to receive related products and services that integrate with, or complement, the Services we offer. We will only share your information with third parties for this purpose if you choose to request their products or services.

We do not control the use, storage, retention, processing, or disclosure of your information by such third parties, and this Privacy Policy will not apply to them. Your relationship with these third parties will generally be subject to their separate terms and conditions as well as privacy policies or statements, and we recommend that you carefully review these documents before requesting their products or services.

When you use our Services, we and our service providers may place cookies (data files on your phone or mobile device's drive), including Google Analytics, or web beacons (electronic images that are placed in a web page's code) or similar technologies. We use cookies to help us identify you as a user, track users' movements around SparkLease, analyze trends, and gather demographic information about our user base as a whole, to provide you a better experience on SparkLease, to measure promotional effectiveness and to ensure trust and safety on SparkLease.

Your Personal Information may also be used to:

• protect or defend our interests and legal right or property of SparkLease;
• protect the rights, interests, safety, and security of users of the sites or members of the public;
• abide with any governmental authority as part of an investigation;
• abide with any court order, subpoena, discovery request, or other lawful judicial or administrative proceedings;
• protect against fraud or for risk management purposes; and/or
• comply with prudent legal practices and applicable law or legal processes.

We take administrative, technical and physical measures to safeguard your personal information against unauthorized access, unauthorized disclosure, theft and misuse. This includes limiting access of employees to, firewalls, data encryption, and the use of passwords and graduated levels of clearance in handling administrative control of the data and servers.

We have internal policies and security standards to help protect our systems and your Personal information against unauthorized access and use. We educate our employees with respect to their obligations to protect your personal information. Our service providers and agents are contractually bound to keep your Personal Information confidential and must not use it for any unauthorized purpose.

Although we take precautions against possible breaches of our security systems, no company can fully eliminate the risks of unauthorized access to your personal information and no website is completely secure. We cannot guarantee that unauthorized access, hacking, data loss or breaches of our security systems will never occur.

We retain your information for as long as necessary to fulfill the purposes for which we collected the information or as required by law. We maintain a records retention and destruction program to destroy information when it is no longer needed or required.

When we no longer need your Personal Information, we may securely destroy, delete, or erase it. We may also convert it to an anonymous form.

Upon request, we will give you access to the information we retain about you. If the information you want concerns any decisions we made about your product or service, we will tell you about the reasons for those decisions unless otherwise prohibited by law.

We make reasonable efforts to keep your Personal Information accurate and up to date. If your information changes, please notify us immediately so that we can make the necessary changes.

You can modify your own information by logging into your Account. When you place a classified ad, you may be able to change your listing or delete your message.

If you want to close your account with us, please contact us at SparkLease Customer Support. We will process your request within a reasonable period of time and process your personal information in accordance with applicable law.

You can request SparkLease destroy, erase or make anonymous personal information when it is no longer required for the purposes for which it was collected by contacting the Privacy Officer at support@sparklease.com. We may, however, retain information about your previous transactions for audit purposes, to ensure the integrity of our data and to fulfill legal requirements.

You may change or withdraw your consent to the collection, use and disclosure of your Personal Information at any time, subject to reasonable notice, by contacting our Privacy Officer, even though that might impact your ability to register or receive a particular product or service.

If you do not want to receive marketing email from us, you can follow the unsubscribe link provided in those emails.

Our website and the services offered on our website are not directed to children under the age of 13 years. We will not knowingly collect personal information about a child under the age of 13.

We do not allow minors (persons who are under the age of majority in their place of residence) to create accounts, make purchases or enter contests or promotions.

If you have any questions regarding this Privacy Policy, or if you wish to access or correct your Personal Information, please contact the Privacy Officer.

Email: support@sparklease.com

Mail:
Privacy Officer
SparkLease Inc.
#405-200 Consumers Rd
North York, ON
M2J 4R4

Access to the Website is provided for personal, non-commercial use only. You may be permitted to post private sale listings for items or vehicles that you personally own, but you may not post listings on behalf of a business except through a commercial account. To set up a commercial account, please contact customer service info@sparklease.com.

When you create a SparkLease account (your "Account") or post content on SparkLease you agree to comply with our Terms of Use and our policies, and agree that we may collect, use and disclose your personal information as described in our Privacy Policy.

You agree to access the Website using only the interfaces that we provide. You may not access the Website by any automated means, including scripts, bots, spiders, etc. You may not attempt to collect or index content or data from the Website using scripts or other automated means.

You may not reproduce content from the Website on other websites, or present our content in HTML "frames" or by similar means. You agree not to attempt to hack, disrupt, gain unauthorized access to, or interfere with the Website, any associated networks or servers, or another user's account.

You may view and print pages from the Website for your own personal use, provided that you do not alter the content and provided that all copyright and trademark notices are included.

In order to access and use some or a portion of the Services, you may be required to register with us and set up an Account with your email address/phone number and a password. You are solely responsible for maintaining the confidentiality of your password and for all activities that occur under your Account.

You may connect to the Services with a third-party service and you give us permission to access, store, and use your information from that service as permitted by that service and as may be described in our Privacy Policy. If you believe your Account may have been compromised or misused, contact us immediately at support@sparklease.com.

You will post in the appropriate category or area and in your use of the Services will not do any of the following:

• violate any laws;
• post content that infringes the rights of third parties;
• post content that contains any reference to or likeness of any identifiable third parties, unless consent has been obtained;
• be false, deceptive, or misleading;
• infringe any third-party right;
• distribute or contain spam, chain letters, or pyramid schemes;
• distribute viruses or any other technologies that may harm SparkLease;
• impose an unreasonable load on our infrastructure;
• copy, modify, or distribute any other person's content;
• harvest or otherwise collect information about others without their consent;
• bypass measures used to prevent or restrict access to SparkLease.

We may allow you to submit comments, ratings, reviews, "for sale" listings, messages to other users, or other content to the Website ("User Content"). When you submit any User Content, you must abide by the following rules:

• Be honest, relevant, and factually accurate. Any opinions that you express must be your own and must be genuinely held.
• Don't post any deceptive or misleading "for sale" listings.
• Don't post anything that violates any applicable law or breaches any contractual or legal obligation.
• Don't post anything that may be defamatory, incorrect, false, misleading, malicious, threatening, abusive, harmful, obscene, offensive, slanderous, racist, libelous, or otherwise objectionable.
• Don't try to solicit anyone else's personal information.
• Don't post spam, including commercial messages for any other person or business.
• Don't post anything that infringes on anyone's intellectual property rights.

SparkLease may remove, modify or delete user submissions, which appear to breach these Terms, or which appear to infringe on the intellectual property rights of others, or for any other reason.

When you submit User Content to the Website, you retain ownership of copyright and other intellectual property rights in that content, but you grant SparkLease a perpetual, irrevocable, worldwide, royalty-free, non-exclusive, transferable and sublicenseable license to use, modify, reproduce, make available, and redistribute it in any form, format or media now known or later developed.

Using the Services is generally free. We may charge fees for certain Services. If the service you use charges a fee, you will be able to review and accept that charge. Our fees are quoted in Canadian Dollars, and we may change them from time to time.

If we charge fees, those fees are non-refundable, and you are responsible for paying them when they're due. If you don't, we may limit your ability to use the Services.

We will collect Canadian taxes associated with our Services when applicable. You are solely responsible for collecting and remit any applicable taxes resulting from the sale of your items or services listed on SparkLease.

The Services contains content provided by us, you, and other users as well as from our third-party service providers. When you give us content, you are granting us a non-exclusive, worldwide, perpetual, irrevocable, royalty-free, sub-licensable right to exercise the copyright, publicity, and database rights to that content in connection with the Services.

We reserve the right to remove content where we have grounds for suspecting the violation of these Terms of Use or the rights of any other party.

We do our best to make sure that the Website is available, functional, error free, and free of malicious code; that your privacy is respected and your personal information and other Website data is secure from inadvertent disclosure or deletion; and that your experience using the Website is positive. But you agree that you use the Website at your own risk. We make no guarantees or warranties of any kind. We provide the Website on an as-is and as-available basis.

You agree that we cannot be held liable for any reason in connection with your use of, reliance upon, or inability to use the Website or any of its features or functionality.

Despite the previous paragraph, if we are found to be liable to you in any manner whatsoever, our liability to you is limited to the greater of (a) the total fees you pay to us in the 12 months prior to the action giving rise to liability, and (b) $10 Canadian Dollars.

All rights in the design, source code, and appearance of SparkLease, and all of the materials and content made available through SparkLease are owned by or licensed to SparkLease. These materials are protected by law against unauthorized copying and reproduction. Any unlicensed use, reproduction or distribution any of this proprietary material is expressly prohibited.

Trade-marks appearing on SparkLease are owned or licensed by SparkLease or its affiliates, or are owned by third parties. You may not use or display these trade-marks except as may be required in order to make use of SparkLease in accordance with these Terms of Use.

We may terminate this agreement at any time by deleting your user Account for breach of these Terms of Use or if you otherwise put SparkLease at risk of legal exposure, or for any other reason, or for no reason, in our sole discretion. The licenses your grant to us, all of your indemnities to us, and all terms disclaiming or limiting our liability shall survive termination of this agreement.

You will indemnify and hold harmless SparkLease and our affiliates and our and their respective officers, directors, agents and employees (each an "Indemnified Party"), from any claim made by any third-party, together with any losses, damages, costs, expenses or other amounts payable to the third-party whether in settlement or as may otherwise be awarded, including all legal costs (on a full indemnity basis) incurred by any of the Indemnified Parties, arising from or relating to your use of the Services.

Any correspondence or business dealing with any third parties, including merchants, sellers, service providers, or advertisers found on, or through, SparkLease are solely the responsibility of you and such parties. SparkLease is not responsible for any damages you may suffer by corresponding with or entering into transactions with any third parties.

Use caution and common sense when using SparkLease, and when entering into correspondence or purchase or sale transactions with third parties. SparkLease publishes "for sale" listings on SparkLease without verification or endorsement.

SparkLease may contain links to third-party websites or services provided by parties other than SparkLease. These links are for your convenience only and SparkLease does not assume responsibility for the accuracy, reliability or appropriateness of these third-party websites or services.

These Terms of Use and the other policies posted on the Services constitute the entire agreement between us and you. This agreement and all disputes, claims or other matters arising from or relating to your use of the Services, SparkLease or the content on SparkLease will be governed by the laws of the Province of Ontario and the federal laws of Canada applicable therein.

Your notices to us must be sent by registered mail to:

SparkLease Inc.
#405-200 Consumers Rd
North York, ON
M2J 4R4
Re: User Inquiries

We may update the Terms of Use and our policies at any time, and any amendments to them will be effective from the time they are posted on SparkLease or a notice is sent to you by email. Your continued use of SparkLease after that time will be deemed to indicate your acceptance of the amended agreement.

Cookies and similar technologies are very small text documents or pieces of code, which often include an anonymous unique identifier. When you visit a website or use a mobile application, a computer asks your computer or mobile device for permission to store this file on your computer or mobile device and access information from it.

When we use the word "cookies" we are referring to all of the above technologies.

We use cookies for a number of reasons including:

• Operating the Website
• To understand your browsing sessions on our Website
• To see which features of our Website are most popular by counting the number of visitors to a page
• To provide you with a more satisfying experience

The cookies we use generally fall into one of the following categories:

Essential Cookies - Cookies that are essential for the operation of the Website.

Session Cookies - Allow the Website to uniquely identify your browsing session on our Website, which allows us to coordinate this information with data from our Website server.

Analytics Cookies - We use this information to improve the Website. Analytic cookies and other information allows us to calculate the aggregate number of people using the Website and see which features of our Website are most popular.

By using the Website, you agree that we may store and access essential cookies on your computer or other devices. You also agree to us storing and accessing certain non-essential cookies that allow us additional functionality or to gather additional information about your use of our Website.

Please see below if you wish to block or delete cookies, or if you would like to withdraw consent to our use of non-essential cookies.

Visitors are provided with the option to navigate to a variety of external websites. When visitors select the option to view content from these websites, they are directed away from the SparkLease website and to the other site, where a variety of cookies may be used throughout the visit. SparkLease is not responsible for any cookies used once a visitor leaves the SparkLease website.

Your browser may provide you with the option to refuse some or all browser cookies. For more information about how to manage browser cookies, please follow the instructions provided by your browser.