Dealer Lister — Privacy Policy

1. Who we are and what this policy covers

Dealer Lister is the operating name of 28523779 AB LTD., an Alberta corporation ("Dealer Lister," "we," "us"). We provide software and marketing services that help vehicle dealerships list inventory on Facebook Marketplace and other online platforms.

This policy explains how we collect, use, share and protect personal information. It applies to:

• People who visit our website or contact us.
• Dealerships that subscribe to our platform, and their staff who use it.
• Personal information about a dealership's customers or leads that passes through our platform.

We follow Alberta's Personal Information Protection Act (PIPA) and, where it applies, the federal Personal Information Protection and Electronic Documents Act (PIPEDA).

2. What information we collect

We collect only what we need to provide and support our services.

3. Why we use it, and consent

We use personal information to:

• Set up and manage accounts, and verify who is using them.
• Create, post and track listings, and run ad campaigns where a Plan includes them.
• Bill for our services, collect payment and keep tax and financial records.
• Provide onboarding, training and customer support.
• Send service notices, such as billing reminders, policy changes and outage alerts.
• Keep the platform secure, prevent fraud and misuse, and fix problems.
• Understand how the platform is used, in combined or de-identified form, so we can improve it.
• Meet our legal obligations.

We don't sell personal information, and we don't use it for purposes unrelated to our services without asking first.

Consent. By signing up, using the platform or contacting us, you consent to the uses above. We will ask for separate consent before using your information for a new purpose. We only send marketing emails, such as news about new features, in line with Canada's Anti-Spam Legislation (CASL), and every marketing email includes a way to unsubscribe. You can withdraw consent at any time by emailing support@dealerlister.com, but withdrawing consent may mean we can no longer provide some or all of our services.

4. Who we share it with

We share personal information only as needed to run our services:

• Service providers who work for us, such as web hosting, cloud storage, payment processing, email, customer support and accounting tools. They may use the information only to provide services to us and must protect it.
• Platforms you connect, such as Facebook Marketplace, when you direct us to post listings or run ads. Their own privacy policies then apply to what they receive.
• Professional advisers, such as our accountant and lawyer, where needed.
• A buyer or successor, if our business is sold, merged or reorganized, under a confidentiality agreement.
• Authorities, where the law requires or permits it, such as a court order or a tax audit.

Service providers outside Canada. Some of our service providers store or process information outside Canada, including in the United States. When information is outside Canada, it may be accessed by courts, law enforcement and government authorities under the laws of that country. You can ask our Privacy Officer (section 10) for written information about how we handle service providers outside Canada, or questions about how they collect, use, disclose or store personal information for us.

5. Dealers' customer information

When a dealership uses our platform to handle information about its own customers or leads, the dealership is responsible for that information. It decides what is collected and how it's used. We handle it on the dealership's behalf, only to provide our services and as the dealership instructs.

Each dealership is responsible for getting any consent its customers must give and for answering their privacy questions. If one of a dealership's customers contacts us, we'll refer them to the dealership, and help the dealership respond where we can.

We don't contact a dealership's customers for our own purposes or use their information to market to them.

6. Cookies and similar tools

Our website and platform use cookies and similar technologies to keep you logged in, remember your settings, keep the platform secure, and understand which pages and features are used. We may use analytics tools that collect usage data on our behalf.

You can block or delete cookies in your browser settings. Some features, including logging in, may not work without them.

7. Keeping information safe

We protect personal information with reasonable safeguards suited to how sensitive it is, including:

• Encrypted connections (HTTPS) and secure, access-controlled hosting.
• Limiting access to staff and service providers who need it to do their jobs.
• Password protection and account permissions for each Team Member.
• Confidentiality commitments from our staff and service providers.

No method of storing or sending information online is completely secure, so we can't guarantee absolute security. Dealerships also play a part by keeping logins private and removing access for staff who leave.

If a breach happens. If personal information under our control is lost or accessed without authorization, and there is a real risk of significant harm, we will notify the Office of the Information and Privacy Commissioner of Alberta and the people affected, as PIPA requires. Where the information belongs to a dealership's customers, we'll notify the dealership promptly so it can meet its own obligations.

8. How long we keep information

We keep personal information only as long as we need it for the purposes in this policy, or as the law requires.

When we no longer need information, we securely delete it or remove anything that identifies a person.

9. Seeing or correcting your information

You can ask to see the personal information we hold about you, how it has been used, and who it has been shared with. You can also ask us to correct information that's wrong or incomplete.

Send your request in writing to our Privacy Officer (section 10). We may ask you to confirm your identity first. We'll respond within 45 days, as PIPA requires, or tell you if we need more time and why. Access is free in most cases; if a fee applies, we'll tell you the estimated cost before we proceed.

In some cases the law lets us, or requires us to, refuse access, for example where the information would reveal someone else's personal information or is subject to legal privilege. If we refuse, we'll explain why and how you can ask for a review.

10. Contact, complaints and updates

Privacy Officer. Our Privacy Officer is responsible for how we handle personal information and for answering questions, requests and complaints.

Attention: Privacy Officer
Dealer Lister (28523779 AB LTD.)
Edmonton, Alberta
support@dealerlister.com (subject line: "Privacy")

Complaints. Please contact us first so we can try to resolve your concern. If you're not satisfied with our response, you can contact the Office of the Information and Privacy Commissioner of Alberta, or the Office of the Privacy Commissioner of Canada where federal law applies.

Changes to this policy. We may update this policy as our services or the law change. We'll post the new version on our website with a new effective date, and tell subscribing dealerships by email about significant changes before they take effect.