Global Privacy policy - Can-Am Off Road
Last Updated: September 18, 2023
At BRP, we recognize the value of privacy. That’s why we protect the personal information entrusted to us. It’s our job to handle it with extreme care and do everything we can to protect it.
This Privacy Policy is to inform you about what we do with your personal information. We invite you to read this Privacy Policy. If you reside in the United States, the province of Québec, the European Union, the United Kingdom, Switzerland, or China, please also read country-specific additional privacy policies in the dedicated section at the end of this Privacy Policy.
This Privacy Policy does not apply to you if you are applying to a position at BRP, please refer to the privacy notice presented to you during the application process.
OUR PRIVACY POLICY IN A NUTSHELL
Who We Are
Bombardier Recreational Products Inc. (together with its affiliate companies and subsidiaries, “BRP”, “we”, “us”) is a global leader in the world of powersports vehicles and propulsion systems, which carries some of the following brands:
- ALUMACraft®
- Can-Am®
- Lynx®
- Manitou®
- Quintrex®
- Rotax®
- Sea-Doo®
- Ski-Doo®
What is Personal Information
Personal information is any information that identifies you directly (for example, your first and last names), or indirectly by combining or associating several information about you (for example, your car plate and your home address).
What We Collect About You
- Information you provide us with, for example when you are completing a form online on our websites and mobile apps;
- Information shared by our dealers and distributors, for example when you purchase our products and services;
- Information automatically collected, for example via cookies when you are browsing on our websites and mobile apps.
What We Do with Your Personal Information
We use your personal information for various reasons, mostly to:
- Provide you with the product or service you requested;
- Register your BRP product;
- Offer you customer support;
- Send you commercial communications about our products and services;
- Perform analytics to have insights on how to improve our products and services;
- Offer you personalized experience, content, or offers and services based on profiling or geolocation technologies.
Who Do We Share Your Personal Information With
Your personal information can be shared where necessary to the following categories of recipients:
- BRP affiliates and subsidiaries;
- BRP dealers and distributors;
- BRP services providers e.g., payment providers, cloud providers, transportation/shipment providers;
- BRP agents or contractors;
- BRP partners e.g., market research partners;
- Social media platforms;
- Law enforcement and other regulatory authorities when we are required by law to disclose your personal information to them.
When disclosing your personal information results in its transfer outside of your country of residence, we implement specific safeguards which are explained in the following sections of this Policy: COUNTRY-SPECIFIC ADDITIONAL PRIVACY POLICIES and HOW DO WE PROTECT YOUR PERSONAL INFORMATION.
Your Privacy Rights
The rights you have depend on your country of residence and on which laws or regulations apply to your situation, but in most cases, you have the right to:
- Request that we confirm if we hold personal information about you and give you access to it;
- Rectify your personal information when inaccurate or no longer up to date;
- Ask a question about how we handle your personal information;
- Make a complaint in relation with our handling of your personal information;
- Ask us to no longer send you our commercial communications.
To know about any additional privacy rights you may have, please read the following sections: YOUR RIGHTS OVER YOUR PERSONAL INFORMATION and COUNTRY-SPECIFIC ADDITIONAL PRIVACY POLICIES.
How To Contact Us
To exercise your privacy rights or ask us anything about this Policy or how we handle your personal information, you can reach the BRP Privacy Officer in any of the following ways:
- Email: privacyofficer@brp.com
- Postal mail:
Bombardier Recreational Products Inc.
Attention: Legal Services
726, St-Joseph Street
Valcourt, Quebec
J0E 2L0
Canada
- Phone: at 1-888-272-9222
- Online Privacy Rights Portal (upcoming)
How and When We Collect Your Personal Information | Type of Personal Information We Collect About You |
Information you provide:
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When we process your payment information, it is usually managed by a third party via secure methods and not stored in our systems. |
Information collected automatically: When you navigate on our websites or mobile apps via cookies or similar technologies for which your consent is not required – Please see the HOW DO WE USE COOKIES AND SIMILAR TECHNOLOGIES section to know more. |
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Information collected from other sources: We may receive information about you from:
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BRP handles your personal information as described below:
Our Reasons | In Detail |
Manage your order of BRP products and services, bought from us directly or from our dealer’s and distributor’s network |
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Personalize your experience, our products and services and interactions with you |
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Manage your BRP products registration, warranty, security, safety recall, and dispute resolution |
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Provide customer support, assistance, and after-sales |
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Send commercial communications |
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Perform online behavioural advertising through cookies and similar technologies |
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Perform data analytics and statistics for business intelligence |
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Prevent, detect, and control fraud and any unauthorized or illegal activities |
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Your personal information will be shared with BRP employees who have a need to know to perform their duties as well as authorized third parties. Therefore, the following categories of recipients access your personal information where necessary for the justifications below:
Categories of Recipients Who May Have Access to Your Personal Information | Why They Need to Have Access to Your Personal Information |
BRP affiliates and subsidiaries |
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Service providers:
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Agents or contractors |
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Advertising & market research partners |
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Social media platforms:
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BRP provides your email in a secure manner. The information shared with social media platforms (including Facebook/Meta) will be used to measure the effectiveness of BRP’s advertising campaigns and will be used by the social media platform for their own purposes. You can limit these disclosures by opting out of online behavioural advertising. You may do so by modifying or adjusting your ad settings (e.g., on Facebook/Meta) to be removed from custom audience lists. |
BRP authorized dealerships and distributors |
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Other third parties |
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Law enforcement or governmental agencies and external auditors |
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We take the following measures when sharing your personal information with recipients:
- We use a consistent security protocol with them;
- We require them to have privacy and security standards that are comparable to ours;
- We implement through our agreements with them, contractual protections and other measures to maintain the confidentiality and security of your personal information and to prevent it from being used for any other purpose. For example, we generally require our service providers to limit their use and retention of personal information to what is necessary to provide their services and to notify us in case of any actual or suspected confidentiality incident involving personal information;
- We have a due diligence process to ensure they are compliant with our requirements. This includes assessing their security practices, data protection policies, and compliance with relevant regulations;
- Access is strictly limited to only those persons who need to use it for the relevant purpose;
- When your personal information is made accessible or is transferred to a third party located outside your country of residence, we implement additional contractual safeguards to ensure that your personal information remains protected. Please read the COUNTRY-SPECIFIC ADDITIONAL PRIVACY POLICIES to know more about the safeguards we implement as they can vary from a country to another.
Your personal information is only retained as long as necessary to achieve the purposes for which it was collected or used or as otherwise permitted or required under applicable laws.
We retain your personal information for:
- the purposes described in this Privacy Policy;
- the purposes communicated to you before or at the time your personal information is collected;
- our own legitimate business needs;
- complying with our legal or regulatory obligations;
- establishing, exercising or defending our legal rights;
- preventing, detecting, and investigating fraud.
If your personal information is needed for more than one purpose, we will retain it until the end date of the purpose with the longest duration. In any case, we will discontinue any use of information for purposes with earlier end dates as soon as such dates are reached.
Personal information that is no longer needed is either irreversibly anonymized or securely destroyed in accordance with applicable laws.
To learn more about our retention and destruction policies and practices, including the period of time that your personal information will be kept, you can contact our Privacy Officer as described in the HOW TO CONTACT US section at the beginning of this Policy.
In addition to the protective measures detailed in the WHO WE SHARE YOUR PERSONAL INFORMATION WITH section, BRP ensures that your personal information is protected against loss and unauthorized access, use or disclosure throughout its life cycle. Your personal information is kept secured and access is strictly limited to only those persons who need to use it for the relevant purpose. BRP employs physical, technical, and organizational measures to ensure your personal information receives an adequate level of protection while it is under our care, including when your personal information is transferred to one of our recipients located outside of your country of residence.
Our websites or mobile applications may offer links to third-party websites. The operators of linked websites may also collect your personal information (including information generated through the use of cookies and payment information) when you use their websites. To the extent permitted by applicable law, BRP is not responsible for how such third parties collect, use, or disclose your personal information. It is important to familiarize yourself with their privacy policies before providing them with your personal information.
BRP’s websites, applications, web apps, products, and services are not targeted to or intended for use by children. We do not knowingly collect personal information from children under the age of 16. Children under this age should not register nor provide BRP with any personal information without the consent of a parent or legal guardian.
If you think we have received personal information from children under the age of 16, please contact us as described in the HOW TO CONTACT US section at the beginning of this Policy.
The rights you have depend on your country of residence and on the laws or regulations that apply to your situation, but in most cases, you have the right to:
- Request that we confirm if we hold personal information about you and give you access to it;
- Rectify your personal information when inaccurate or no longer up to date;
- Ask a question about how we handle your personal information;
- Make a complaint in relation with our handling of your personal information;
- Ask us to no longer send you our commercial communications.
Please read the dedicated section in the COUNTRY-SPECIFIC ADDITIONAL PRIVACY POLICIES to know more about other privacy rights you may have.
Commercial Communications
We use your contact information to communicate with you by email or other means of electronic communication, such as text messages or phone. You can always ask us to stop sending you commercial communications. The simplest way to do so is to withdraw your consent, which you can do at any time, either by clicking the unsubscribe link at the end of any newsletter or commercial communication or by contacting our Privacy Officer as described in the HOW TO CONTACT US section at the beginning of this Policy.
However, when you withdraw your consent from receiving commercial communications from BRP, you may continue to receive commercial communications from our dealerships and distributors, who have their own independent consent management system. The reverse is also true; you may continue to receive commercial communications from us when you unsubscribe only to those sent by our dealerships and distributors.
Other Rights Specific to the Use of Certain BRP Websites or Mobile Applications
When you use certain of our mobile applications or websites, depending on their functionalities, you can:
- Modify your profile to ensure that only certain information appears to other users;
- Decide not to provide some of the information requested (it may limit some of the uses and functionalities available to you);
- Deactivate or block the sharing of your location when you use the website or mobile application, including when participating in group riding events;
- Modify your location settings and the location permissions in your device settings, to ensure that your location is only shared by your device to the application during your utilization of the application. If you further limit access to location information, this may prevent you from using some or all of the functionalities of the website or application;
- Accept or refuse to receive push notifications relating to the website or mobile application, which are sent to alert you of new information;
- Delete the mobile application at any time or delete your account. If you do so, it will result in the deletion of certain information, such as your planned and completed rides, riding statistics, points of interest, saved locations and friends where applicable.
How You Can Exercise Your Rights
If you wish to exercise any rights listed above or in the dedicated section in the COUNTRY-SPECIFIC ADDITIONAL PRIVACY POLICIES, you may make a request by contacting our Privacy Officer as described in the HOW TO CONTACT US section at the beginning of this Policy. BRP may require relevant information or details in order to properly authenticate you. Once available, you will also be able to directly submit your privacy requests online through our Online Privacy Rights Portal (upcoming).
If you want to exercise a right specific to the use of certain BRP websites or mobile applications, you can do so by following the procedure listed in the terms and conditions of the website or mobile application you are using.
Please note that applicable laws may restrict or limit your rights, which means that in some situations as permitted by applicable laws, we are entitled to deny your request. In any case we will explain to you the reason why we cannot fulfill your request as permitted by law.
Only you or an authorized representative may make a verifiable consumer request related to your personal information. You may be required to submit proof of your identity to make a privacy right request and we may not be able to comply with your request if we are unable to confirm your identity or to connect the information you submit in your request with personal information in our possession.
We do not charge a fee to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Complaint Resolution
We are committed to working with you to resolve any concern you may have about our use of your personal information or to obtain a fair resolution to any complaint. If, however, you believe that we have not been able to assist with your complaint or concern, you may have the right to lodge a complaint with the data protection authority in your country or supervisory authority. Please refer to the dedicated section in the COUNTRY-SPECIFIC ADDITIONAL PRIVACY POLICIES for more details.
This Privacy Policy will be modified from time to time. In this case, we will keep you informed by updating the “Last Updated” date at the top of this Privacy Policy or by any other means of communication where appropriate. We recommend that you check occasionally this website to inform yourself of any changes.
What Is a Cookie?
A cookie is a small text file placed on your computer or device when you visit a website. It is usually created when a new webpage is loaded.
Cookies store information on your computer or device in order to manage your website experience. They are designed to hold a small amount of data specific to a particular user and website to allow web pages delivered to be tailored to a particular user. Some pages contain a script which takes into consideration the data in the cookie, and so is able to carry information from one visit to the website (or related website) to the next. Cookies also store preference information to customize your website experience. Most web browsers allow you to control cookies through their settings preferences.
Cookies and Other Tracking Technologies Used by BRP
Strictly Necessary Cookies
| These cookies are always active as they are necessary for the functioning of the website/mobile application. They are in response to actions you have taken such as logins, language preferences, browser settings, and auto-fill forms. You can set your browser to alert you when these cookies are being used or to block them. Please be aware that some parts of the website/mobile application may not work if you block these cookies. |
Facebook/Meta Pixel | These cookies are provided by Facebook/Meta and help us measure the effectiveness of our advertisements by understanding what actions visitors take when they visit our websites or mobile applications. This allows us to create custom audiences on the social media platform and serve advertisements to users who match the characteristics of these audiences. You can manage your privacy and ads preferences through your account settings on Facebook/Meta. |
Marketing Cookies | These cookies are used by BRP and third parties to build a profile of your interests, show you relevant communications, as well as to understand the performance of the advertising. They track information such as browser and device identifiers, the number of unique visitors, the number of clicks on ads, and most recently loaded pages. They are also used to build consumer profiles, including showing ads based on products that are viewed or acts that have been taken on BRP websites/mobile applications. By disabling these cookies, you will not receive a targeted advertising experience across different websites/mobile applications. |
Analytics Cookies | We use analytics service providers, such as Google Analytics to obtain aggregated or statistical data about the actions taken by visitors to our websites or mobile applications. This helps us understand how our websites and mobile applications are used and improve our services. You can opt out of Google Analytics by using a browser add-on. We also use services that enable us to better understand our users’ needs and optimize our platform and users’ experience. These services use cookies and other technologies to collect data on:
This information is stored in a pseudonymized user profile, and it will not be used to identify individual users or to match it with further data on an individual user. |
Retargeting/Behavioural/Statistical Cookies | These cookies are used by BRP and third parties to create audiences that include lists of users who have interacted with the BRP website/mobile application in a particular fashion. These cookies do not contain any identifiers nor any personal identifiable information. |
Clear GIFs | Clear GIFs (a.k.a. web beacons, web bugs or pixel tags) are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, though, clear GIFs are embedded invisibly on web pages, not stored on your hard drive. These “images” are automatically loaded to your browser/device when you visit our website or open an HTML-format email message from us, thereby letting us know if a certain page was visited or an email message was opened. Clear GIFs allow us to record simple user actions related to our websites and to email communications received from us, to help us determine the usage and effectiveness of our site and communications. We might use clear GIFs to track the activities of our visitors, help us manage content, and compile statistics about usage. We and our third-party service providers also might use clear GIFs in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded. These can be blocked either by using a third-party applications or in the case of emails, by changing your settings to prevent images from being downloaded (where your email client supports this functionality). |
Your Cookie Settings
You can completely disable some or all cookies in the advanced settings of your browser at any time. To learn more on BRP’s use of cookies, you may refer to our Cookie Policy.
This section supplements the information contained in our Privacy Policy and applies solely to clients, visitors, users, and others who reside in the states of California, Virginia, Connecticut, Colorado, and Utah (“consumers” or “you”).
Information We Collect and Handle
BRP US Inc., as the controller of your personal information, together with Bombardier Recreational Products Inc., handles the following categories of personal information as indicated with a “Yes” below:
Category | Collected by BRP? | Disclosed by BRP to third parties in the last 12 months, including for a business purpose? | Examples |
Category A – Identifiers | Yes | Yes | Full name, address, email address. |
Category B – Personal information, including as defined in the California Civil Code Section 1798.80(e) | Yes | Yes | Name, signature, address, telephone number, driver’s license or state identification card number, employment, other financial information. |
Category C – Characteristics of protected classification under states laws (including federal) | Yes | Yes | Age, gender. We have access to age brackets and gender information on an aggregated basis through Google Analytics, which we use for statistical purposes. |
Category D – Commercial | Yes | Yes | Transaction information, purchase history such as records of vehicles, product or services purchased, purchase tendencies, payment information. |
Category F – Internet or other electronic network activity | Yes | Yes | Browsing history, search history, online behaviour, interest data, and interactions with our and other websites, applications, systems, and advertisements. |
Category G – Geolocation | Yes | Yes | Device or vehicle location. |
Category H – Audio, electronic, visual, and similar | Yes | Yes | Service call recordings, images and 3D models created in connection with our business activities. |
Category K – Inferences drawn from any of the personal information listed above | Yes | Yes | To create a profile or summary about, for example, an individual’s preferences and likelihood to purchase our vehicles, products or services. |
Categories A, B, C, D, F, G and K could constitute sensitive personal information, depending on the nature of the services and the context.
Sales of Personal Information
We do not sell your personal information to third parties for their commercial purposes, except when you specifically allow us to do so.
In the last twelve (12) months, we have not sold any personal information. Please also note that any third parties who would purchase the personal information we hold, would be prohibited from reselling it unless you have received explicit notice and an opportunity to opt out of further sales.
Your Rights and Choices
The following rights are in addition to those described in the YOUR RIGHTS OVER YOUR PERSONAL INFORMATION section:
California
- Right to be informed. You have the right to know how your personal information is being handled by BRP and ask us any questions you may have about it.
- Right to request that we disclose to you:
o if we process your personal information and, where applicable, the categories of personal information we collected about you and the categories of sources from which we collected such information;
o the specific pieces of personal information we collected about you;
o the business or commercial purpose for collecting personal information about you; and
o the categories of personal information about you that we shared or disclosed and the categories of third parties with whom we shared or to whom we disclosed such information in the preceding 12 months. - Right to request that we delete personal information we collected from you, subject to certain exceptions.
- Right to not be discriminated against because you exercise any of your rights, by denying you a good or service, by charging you with a different price or rate for a good or service or by providing you with a different level of quality of a good or service.
- Right to direct us not to sell or share your personal information at any time (the “right to opt out”).
- Right to direct us to limit our use and disclosure of sensitive personal information at any time, to that use which is necessary to perform the services or provide the goods.
- Right to request that we correct inaccurate personal information about you, taking into account the nature and the purposes of processing of the personal information.
- Right to not be retaliated against for exercising your rights.
- Right to obtain a copy of your personal information that you have previously provided us in a portable and, to the extent technically feasible, readily usable format.
Virginia
You have all the above rights, as well as the following:
- Right to opt out of the processing of your personal information for purposes of targeted advertising, sale of your personal information or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
Colorado
- Right to be informed. You have the right to know how your personal information is being handled by BRP and ask us any questions you may have about it.
- Right to request that we correct inaccurate personal information about you, taking into account the nature and the purposes of processing of the personal information.
- Right to opt out of the processing of your personal information for purposes of targeted advertising, sale of your personal information (applicable as of July 1st, 2024) or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
- Right to request that we delete personal information we collected from you, subject to certain exceptions.
- Right to not be discriminated against because you exercise any of your rights, by denying you a good or service, by charging you with a different price or rate for a good or service or by providing you with a different level of quality of a good or service.
- Right to obtain a copy of your personal information that you have previously provided us in a portable and, to the extent technically feasible, readily usable format, where the processing is carried out by automated means.
Connecticut
- You have the same rights as the state of Colorado, but you also have the right to not be discriminated against from the processing of personal information that violates state or federal laws prohibiting unlawful discrimination against you. All your rights are applicable as of July 1st, 2023.
Utah (applicable as of December 31st, 2023)
- Right to be informed. You have the right to know how your personal information is being handled by BRP and ask us any questions you may have about it.
- Right to request that we delete the personal information we collected from you, subject to certain exceptions.
- Right to not be discriminated against because you exercise any of your rights, by denying you a good or service, by charging you with a different price or rate for a good or service or by providing you with a different level of quality of a good or service.
- Right to obtain a copy of your personal information that you have previously provided us in a portable and, to the extent technically feasible, readily usable format, where the processing is carried out by automated means.
- Right to opt out of the processing of your personal information for purposes of targeted advertising or sale of your personal information.
Exercising Your Rights
You can exercise these rights by contacting our Privacy Officer and as described in the HOW TO CONTACT US section at the beginning of this Policy.
To exercise the right to opt out and limit the use and disclosure of sensitive personal information, you may also submit a request to us by clicking here: Do Not Sell or Share My Personal Information or here: Limit Use and Disclosure of Sensitive Personal Information.
Appeal
If you reside in California, Colorado, Virginia or Connecticut, you may appeal our refusal to take action on a request within the legal timeframe provided for in the applicable law after you have been notified of our decision. To exercise your right of appeal, you may contact our Privacy Officer as described in the HOW TO CONTACT US section at the beginning of this Policy or call us at 1-888-272-9222.
This section supplements the information contained in our Privacy Policy and applies solely to clients, visitors, users, and others who reside in the Province of Québec (Canada).
Data Governance and Security
BRP maintains governance policies and practices, which ensure the protection of your personal information. In addition to the measures detailed in the WHO WE SHARE YOUR PERSONAL INFORMATION WITH section, depending on the volume and sensitivity of the information, the purposes for which it is used, and the format in which it is stored, we implement a combination of measures to protect your personal information, including:
- Internal policies and procedures defining the roles and responsibilities of our employees throughout the information life cycle;
- Employee privacy and data security training;
- Designating a Privacy Officer to monitor and manage BRP’s compliance with applicable privacy laws. The Privacy Officer’s role and responsibilities include:
o approving internal policies and practices regarding the protection of personal information;
o assisting in conducting privacy impact assessments (when required by law); and
o responding to privacy rights requests in accordance with this Privacy Policy and applicable laws; - Procedures for receiving, investigating, and responding to complaints or inquiries regarding BRP’s personal information handling practices, including any confidentiality incident involving personal information and any request from an individual to exercise their privacy rights;
- Access controls that restrict access to your personal information to employees or service providers who have a business need consistent with the reason the information was provided;
- Generally accepted information security techniques, such as firewalls, data encryption, antivirus software and access control procedures;
- Framework limiting our retention of personal information to what is necessary to achieve the purposes described in this Privacy Policy, including providing you with the products or services requested. This framework also governs the disposal of your personal information and is more fully described in the HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION above.
Transfer of Personal Information Outside of the Province of Québec
For personal information involving Québec residents, transfers of personal information outside the province will be carefully reviewed prior to the transfer and an assessment will be done to ensure that they fall within the limits of applicable law and that the jurisdiction where the personal information is received offers adequate safeguards.
Privacy Rights
As a Québec resident, in addition to the privacy rights described in the YOUR RIGHTS OVER YOUR PERSONAL INFORMATION section, you have other rights in relation to your personal information, such as:
- Right to be informed. When your personal information is collected and subsequently on request, BRP must inform you of:
o the purposes for which your information is collected;
o the means by which the information is collected;
o your right of access and rectification;
o your right to withdraw consent to the communication or use of the information collected;
o the third parties for whom the information is being collected (if applicable);
o the category of third parties to whom it is necessary to communicate your information (if applicable);
o the possibility that the information could be communicated outside Québec (if applicable);
o the personal information that is collected from you (on request);
o the categories of persons who have access to the information within BRP (on request);
o the period of time the information will be kept (on request);
o the contact information of the person in charge of the protection of personal information (on request);
o the source of the information if BRP collects your personal information from another third party (on request). - Right to request to cease dissemination or to de-index your personal information. You may require BRP to cease disseminating that information or to de-index any hyperlink attached to your name that provides access to the information by a technological means, if the dissemination of the information contravenes applicable law or a court order.
- Right not to be subject to automated decision making. If BRP renders a decision based exclusively on an automated processing of your personal information, you have the right to be informed no later than at the time we inform you of the decision. You also have the right to be informed on request of the personal information used to render the decision, the reasons and the principal factors and parameters that led to the decision and to have the personal information used to render the decision corrected. You also have the opportunity to submit observations to a member of the personnel of BRP who is in a position to review the decision.
You can exercise these rights by contacting our Privacy Officer as described in the HOW TO CONTACT US section at the beginning of this Policy.
You may also lodge a complaint with the data protection authority in Québec, the Commission d’accès à l’information du Québec.
This section supplements the information contained in our Privacy Policy and applies solely to clients, visitors, users, and others who reside in the European Union, Iceland, Norway, Lichtenstein, United Kingdom or Switzerland (“Europe”).
Bombardier Recreational Products Inc., having its corporate headquarters at 26 Saint-Joseph St., Valcourt, Québec J0E 2L0, Canada and BRP European Distribution SA., having its corporate headquarters at Avenue d’Ouchy 4-6, 1006 Lausanne Switzerland are considered "data controllers" under applicable laws because BRP determines how and why it handles your personal information.
BRP handles your personal information as described below:
Our Reasons | Our Legal Justifications |
Manage your order of BRP products and services – Bought from us directly or from our dealer’s and distributor’s network | |
| Necessary for the performance of the contract we have with you. |
| Depending on the circumstances either:
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| To comply with our accounting, fiscal, and tax obligations under laws and regulations applicable to us. |
Personalize your experience and our products, services and interactions with you | |
| Depending on the circumstances either:
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Manage your BRP products registration, warranty, security, safety recall, and dispute resolution | |
| Necessary for the performance of the contract we have with you. |
| Depending on the circumstances, either:
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| Our legitimate interest to protect, establish, exercise, or defend our legal rights or in connection any actual or prospective legal proceedings. |
Provide customer support, assistance, and after-sales | |
| Depending on the circumstances, either:
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| Necessary for the performance of the contract we have with you. |
| Depending on the circumstances, either:
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| Our legitimate interest to protect, establish, exercise, or defend our legal rights or in connection any actual or prospective legal proceedings. |
Send commercial communications | |
| Depending on the circumstances, either:
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Perform data analytics and statistics for business intelligence | |
| Depending on the circumstances, either:
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Prevent, detect, and control fraud and any unauthorized or illegal activities | |
| Depending on the circumstances, either:
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Perform online behavioural advertising through cookies and similar technologies | |
| Depending on the circumstances, either:
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International Transfers of Personal Information
If your personal information is transferred outside Europe, the following measures apply:
- Your personal information is transferred to a country considered as providing adequate protection by the European Commission, such as Andorra, Argentina, Canada, Faroe Islands, Guernsey, Israel, Isle of Man, Japan, Jersey, New Zealand, Republic of Korea, Switzerland, the United Kingdom, or Uruguay;
- The European Standard Contractual Clauses (SCCs) under the General Data Protection Regulation 2016/679 (GDPR) have been signed with third parties as the SCCs provide appropriate data protection safeguards. BRP incorporates the SCCs that are annexed to the European Commission’s Implementing Decision 2021/914 of 4 June 2021 for the transfer of personal information to third countries pursuant to GDPR, as well as the SCCs as amended by the International Data Transfer Addendum as issued by the UK Information Commissioner’s Office under S119A (1) Data Protection Act 2018. SCCs are incorporated into the contracts between BRP and third parties who manage personal information on its behalf.
Privacy Rights
In addition to the privacy rights described in the YOUR RIGHTS OVER YOUR PERSONAL INFORMATION section, you or have other rights over your personal information, such as:
- Right to be informed. You have the right to know how your personal information is being handled by BRP and ask us any questions you may have about it.
- Right to object to the processing of your personal information. You can ask BRP to stop processing your personal information including to profiling, and you can opt out at any time from receiving our commercial communications.
- Right to withdraw your consent. Where you formerly gave us your consent, you can withdraw your consent at any time.
- Right to request the restriction of processing of your personal information. You can ask BRP to temporarily freeze or limit the handling of your personal information, for example, if you believe your personal information is inaccurate.
- Right to request the erasure of your personal information ("right to be forgotten").
- Right to request portability of your personal information. You may request to receive your personal information in a structured, commonly used, and machine-readable format or request that your personal information be transferred by BRP to a third party.
- Right not to be subject to automated decision making. You have the right not to be subject to a decision based solely on automated processing, which includes profiling, when that decision produces legal effects concerning you or significantly affects you. In that case, you can ask us to involve someone to review the automated decision, to express your point of view, and to contest the decision.
- Right to define instructions regarding your personal information for its management after your passing. You have the right to designate someone who will give us instructions in relation to your personal information, including a deletion request, in the event of your passing.
You also have the right to lodge a complaint with the data protection authority in your country of residence. You can find your data protection authority online on the institutional website of the European Commission.
You can exercise these rights by contacting our Privacy Officer as described in the HOW TO CONTACT US section at the beginning of this Policy. Please note that any request to stop the processing of your personal information or to have it erased will not be applicable when BRP has the obligation to communicate with you for health or safety related matters, such as safety recall or warranty matters regarding your BRP product(s), or as otherwise permitted under applicable laws.
This section supplements the information contained in our Privacy Policy and applies solely to clients, visitors, users, and others who reside in China.
Unless otherwise stated, the following BRP entities are considered data controllers under applicable laws because each of them determines how and why they handle your personal information:
- Bombardier Recreational Products Inc., having its corporate headquarters at 26 Saint-Joseph St., Valcourt, Québec J0E 2L0, Canada;
- BRP Commerce & Trade (Shanghai) Co Ltd. (Rm 301, Building 6, No.10 Heng Shan Rd, Xuhui District, Shanghai 200031, China).
BRP’s Legal Grounds for Processing Your Personal Information
BRP will process your personal information based on the following legal justifications:
- Your consent is obtained;
- The processing is necessary for the conclusion or performance of a contract with you;
- The processing is necessary for the performance of statutory duties or for compliance with a legal obligation;
- The processing is necessary for coping with public health emergencies or for the protection of the life, health, and property safety of a nature person;
- The information has been publicly disclosed by you or other legally disclosed personal information within a reasonable scope;
- Other circumstances provided by laws and administrative regulations.
Privacy Rights
In addition to the privacy rights described in the YOUR RIGHTS OVER YOUR PERSONAL INFORMATION section, you have other rights over your personal information, such as:
- Right to be informed. You have the right to be provided with clear, transparent, and easily accessible information about how your personal information is being handled by BRP.
- Right to ask us to limit or stop the processing of your personal information. You can ask BRP to limit or refuse the handling of your personal information unless laws or administrative regulations stipulate otherwise.
- Right to withdraw your consent. Where you formerly gave us your consent, you can withdraw your consent at any time.
- Right to request the erasure of your personal information. You have the right to request deletion of your personal information where conditions under applicable law are met.
- Right to request portability of your personal information. You may request, as part of your right to obtain a copy of your personal information, that your personal information be transferred to a personal information handler you designate, where it meets the conditions of the applicable law and BRP must provide a channel to transfer it.
- Right not to be subject to automated decision making. Where BRP conducts information push delivery or commercial sales to you through automated decision-making, you have the right to request that we provide you with the option to not target your characteristics or provide you with a convenient method to refuse. When the use of automated decision-making produces decisions with a major influence on your rights and interests, you have the right to require BRP to explain the matter, and you have the right to refuse that BRP make decisions solely through automated decision-making methods.
International Transfers of Personal Information
When sharing your personal information with third parties in accordance with this Privacy Policy, it may be transferred outside of China. We will always evaluate our legal justification for such transfer and deploy protective measures, as detailed in the WHO WE SHARE YOUR PERSONAL INFORMATION WITH section. We will transfer your personal information in compliance with applicable data protection laws and will implement suitable safeguards.
Last Updated: January 1st, 2023
Table of Content
1. Scope and Purpose
2. Personal Information and Non-Personal Information
3. What Kind of Personal Information Do We Collect
4. How Do We Use Your Personal Information
5. How Do We Share Your Personal Information
6. BRP’s Legal Grounds for Processing Your Personal Information
7. How Long Do We Keep Your Personal Information
8. Cookie Policy
9. How Do We Protect Your Personal Information
10. Links to Third-Party Sites
11. Protecting the Privacy of Children
12. Changes to This Privacy Policy
13. Your Rights Over Your Personal Information
1. SCOPE AND PURPOSE
Bombardier Recreational Products Inc., BRP US Inc., BRP European Distribution SA., (together with their affiliate companies and subsidiaries, "BRP", "we", "us") is a global leader in the world of powersports vehicles and propulsion systems.
We are committed to protecting your privacy and support a general policy of openness about how we collect, use and disclose your Personal Information (as defined below). This Privacy Policy applies to information, including Personal Information collected about you by BRP. The purpose of this Privacy Policy is to inform you about BRP’s practices relating to the collection, use and disclosure of Personal Information that may be provided through access to or use of our websites or services and products or that may otherwise be collected by us.
This Privacy Policy also explains how you can contact us if you have a question about, want to make a change to or would like to delete any Personal Information that BRP may have about you. We strongly recommend that you take the time to read this Privacy Policy and retain it for future reference.
If you are a California or a Virginia resident, the laws of these American states may provide you with additional rights regarding our use of your Personal Information. To learn more about your California and Virginia privacy rights, consult our Privacy Notice for California and Virginia Residents at the end of this Privacy Policy.
2. PERSONAL INFORMATION AND NON-PERSONAL INFORMATION
For the purpose of this Privacy Policy,
(a) “Personal Information” means information about an identifiable individual; and
(b) “Non-Personal Information” means information that cannot be used to identify you (for example, aggregated statistical data).
Non-Personal Information does not constitute Personal Information and any collection or processing of Non-Personal Information is not subject to collection, use or disclosure practices contemplated by this Privacy Policy. Any disclosures regarding Non-Personal Information made in this Privacy Policy are provided for informational purposes only.
3. WHAT KIND OF PERSONAL INFORMATION DO WE COLLECT
Information provided to us by you
We collect information you voluntarily provide to us, such as your name, language of communication, phone number, address, and email address when you want to learn more about BRP products and services, when you become the owner of a BRP product or when you contact our Consumer Services group for assistance with your BRP products or for after-sale service.
Information collected automatically
We automatically collect information about you, such as information collected by cookies and similar technologies when you use our websites or our dealers’ or distributors’ websites. We may, for example, collect information about the type of device you use to access our websites, the operating system and version, your IP address, your general geographic location as indicated by your IP address, your browser type, the webpages you view on our or our dealers’ or distributors’ websites, and whether and how you interact with content available on such websites.
Information collected from other sources
We may receive information about you, such as demographic information, from other sources, including third parties, such as dealers and partners with whom we offer services or engage in joint-marketing activities. We may also receive information about you from social media platforms such as Facebook and Twitter, for instance, when you interact with us on those platforms. We protect data obtained from third parties according to the practices described in this Privacy Policy and we also apply any additional restrictions imposed by the source of the data.
Information collected from your interactions with BRP
We have highlighted different occasions when BRP could potentially collect Personal Information from customers. The customer interactions with BRP are broken down into the following segments:
Learning about BRP
As you gather information about BRP, you may virtually or physically visit a site, browse our website, call our in-house sales representatives, physically visit a BRP-owned store, subscribe to BRP’s newsletters, participate in BRP-sponsored contests and sweepstakes or attend BRP-sponsored events. To learn more about BRP products, you may voluntarily provide Personal Information, such as your name, address and email address during these interactions. We may also collect information about you online via cookies or similar technologies when you visit our websites. Subject to our obligations under applicable anti-spam laws, we use this information to share news about events and about products offered by BRP. Additionally, IP addresses help us to better understand geographic information about visitors to our websites so that we can improve our websites for everyone.
It is our legitimate interest to process your Personal Information for these purposes.
Buying BRP products
If you decide to buy a BRP product, we offer ways for you to buy directly from us via our websites or at a BRP dealership. When you buy from us, you will be asked to provide information so that we can complete your purchase. We use this information to complete your transaction, follow up with you about your purchase, help with any delivery issues, handle returns, offer after-sale service, and other issues related to your purchase of BRP products.
Processing your Personal Information for this purpose is necessary for performance of the agreement we have with you.
Please note that we do not store any payment or credit card information. We only use payment information in connection with purchases of BRP products.
Registering your BRP products
As part of registering your BRP product for ownership, safety recall and warranty purposes, BRP will collect information such as your name, address, and email address. You are required to provide this information to register your BRP product. We collect this information to help establish ownership of individual BRP products, perform any safety recalls, and offer warranty and after-sale service to you.
It is our legitimate interest, and of vital interest to you in terms of safety recalls, to process your Personal Information for these purposes.
Getting help from BRP
From time to time, you may decide to contact our Consumer Services group for assistance with your BRP products. To be able to offer you the best service possible, we may collect certain data from you or your BRP products. We collect this information to give you the best and most efficient customer support possible.
It is our legitimate interest to process your Personal Information for these purposes.
4. HOW DO WE USE YOUR PERSONAL INFORMATION
BRP uses the data we collect to provide you with information on the BRP products and services we offer, which includes using data to improve and personalize your experience. We also use the data to communicate with you, for example, to advise you about your account, new BRP products or services available, security and other types of updates. BRP uses the data for the following purposes:
Customer support
We use data to respond to customer inquiries, diagnose product problems, repair customers’ BRP products, and provide other customer care and support services.
Security, safety, and dispute resolution
We use data to protect your security and safety, to detect and prevent theft, to resolve disputes, and to enforce our agreements.
Communication, personalization, marketing and advertising
We use the data we collect to deliver and personalize our communications with you. For example, subject to our obligations under applicable anti-spam laws, we may contact you by email or other means of electronic communication to inform you about new BRP products or services, to provide you with personalized service, to update you on a support issue or to invite you to take part in a survey.
Sales and after-sales
Our sales and after-sale services will use your data to process your purchase and configure and service your BRP product. We will obtain your contact information, vehicle information, configuration details, and sales and service information when you purchase, service or repair a vehicle from or through our vehicle sales and after-sale services as part of the sale or service and will use it to provide the services you request and notify you of issues in relation to your vehicle. This information may be accessed by BRP to troubleshoot technical or other issues relating to the delivery of these services, to help continuously improve product quality, to cross-check information in certain circumstances such as in connection with warranty claims or to check if recalls have been property performed.
Employment and recruiting
When you submit a job application, we will collect and process your Personal Information for recruiting-related purposes, to manage your application, to determine if your application matches the role for which you applied, to communicate with you regarding your application or opening beyond the scope of your original application, and in order to better understand who is applying to BRP positions and how to better attract applicants for BRP vacancies.
Non-Personal Information
We also use Non-Personal Information. For example, we may:
(a) collect and analyze aggregated and/or de-identified information to produce statistical data for research purposes and to develop and improve our BRP products and services, including maintaining and improving the performance of our BRP products and services, developing and adding new features or capabilities;
(b) use cookies and similar technologies to provide the most relevant BRP advertising to you. Using cookies and collected data, we may create audiences that include lists of users and share them with authorized third parties in order to reach people who may have similar interest as those who interacted with BRP websites; and
(c) develop aggregate analysis and business intelligence that enable us to operate, protect, make informed decisions, and report on the performance of our business.
5. HOW DO WE SHARE YOUR PERSONAL INFORMATION
Personal Information BRP has collected may be transferred to a limited range of third parties. In this case, your Personal Information will be shared with these agents or contractors, but only for the purpose of performing services on behalf of and under instruction from BRP, and in accordance with this Privacy Policy.
The information is shared in a secure manner, using a consistent security protocol between BRP and the third parties. When BRP shares information with other parties, we ensure that they only use your Personal Information for the purposes for which it was provided in accordance with this Privacy Policy.
The types of third parties that we share information with are:
· BRP affiliates and subsidiaries;
· Selected marketing agencies, including call centers, which execute marketing campaigns on BRP’s behalf;
· BRP authorized dealerships and distributors;
· Printing vendors;
· Recruiting agencies (solely with respect to data collected in the context of recruitment); and
· Any third party authorized by us or by you to process Personal Information for the purposes contemplated in this Privacy Policy.
BRP may also disclose and/or transfer Personal Information to a third party in the event of a proposed or actual purchase, sale (including a liquidation, realization, foreclosure, or repossession), lease, merger, amalgamation, joint venture, strategic partnership or any other type of acquisition, disposal, transfer, conveyance, or financing of all or any portion of BRP, or of any of the business or assets or shares of BRP or a division thereof, in order for you to continue to receive the same products and services from the third party.
We may also disclose Non-Personal Information in a number of circumstances including, but not limited to, the circumstances identified above.
6. BRP’S LEGAL GROUNDS FOR PROCESSING YOUR PERSONAL INFORMATION
BRP will use your Personal Information described above as permitted by the different privacy laws in the countries where we operate. As such, to the extent permitted by applicable privacy laws, BRP will abide by the following principles:
· BRP has obtained your consent;
· It is necessary for the performance of a contract;
· BRP has a legal obligation to process your Personal Information;
· There is a vital interest for a data subject;
· A task is carried out in the public interest; and
· There is a legitimate interest for BRP to process your Personal Information, except where such interest is overridden by your fundamental rights and freedoms.
BRP reserves the right to disclose Personal Information to a third party if a law, regulation, search warrant, subpoena, or court order requires or authorizes us to do so.
7. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION
Your Personal Information is retained only for as long as necessary for the purpose for which we obtained it and for any other permitted ancillary purposes. If information is needed for more than one purpose, we will retain it until the end date of the purpose with the longest duration; however, we will discontinue any use of information for purposes with earlier end dates as soon as such dates are reached.
Your Personal Information is kept secured and access is strictly limited to only those persons who need to use it for the relevant purpose.
Our retention periods are based on business needs and Personal Information that is no longer needed is either irreversibly anonymized or securely destroyed.
8. COOKIE POLICY
What is a cookie?
A cookie is a small text file placed on your computer when you visit a website. It is usually created when a new webpage is loaded.
Cookies store Non-Personal Information on your computer in order to manage your website experience, such as your web browser type. They are designed to hold a small amount of data specific to a particular user and website to allow web pages delivered to be tailored to a particular user, or some pages to contain some script which takes into consideration the data in the cookie and so is able to carry information from one visit to the website (or related website) to the next. Cookies also store preference information to customize your website experience. Most web browsers allow you to control cookies through their settings preferences.
We use cookies to manage BRP’s websites and email programs.
Cookies and other tracking technologies used on BRP’s websites
Strictly Necessary Cookies
Always Active – These cookies are necessary for the functioning of the website. They are in response to actions you have taken such as log-ins, language preferences, browser settings, and auto-fill forms. You can set your browser to alert you when these cookies are being used or to block them. Please be aware that some parts of the website may not work if you block these cookies.
Facebook Pixel
These cookies are used by BRP and Facebook to measure, build, and improve Facebook advertising audiences. This works by uniquely identifying your browser and device and ensuring that BRP displays its Facebook advertising campaigns to users that would be interested in such advertising. This is done by analyzing which content is interacted with by a user.
Marketing Cookies
These cookies are used by BRP and third parties to build a profile of your interests, show you relevant communications, as well as to understand the performance of the advertising. They track information such as browser and device identifiers, the number of unique visitors, the number of clicks on ads, and most recently loaded pages. They are also used to build consumer profiles, including showing ads based on products that are viewed or acts that have been taken on BRP websites. By disabling these cookies, you will not receive a targeting advertising experience across different websites.
Retargeting/Behavioral/Statistical Cookies
These cookies are used by BRP and third parties to create audiences that include lists of users who have interacted with the BRP website in a particular fashion. These cookies do not contain any identifiers nor any personal identifiable information.
Your cookie settings
You can completely disable some or all cookies in the advanced settings of your browser at any time. For more information on how to disable cookies.
Clear GIFs
Clear GIFs (a.k.a. web beacons, web bugs or pixel tags) are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, though, clear GIFs are embedded invisibly on web pages, not stored on your hard drive. These “images” are automatically loaded to your browser/device when you visit our website or open an html format email message from us, thereby letting us know if a certain page was visited or an email message was opened. Clear GIFs allow us to record simple user actions related to our websites and to email communications received from us, to help us determine the usage and effectiveness of our site and communications. We might use clear GIFs to track the activities of our visitors, help us manage content, and compile statistics about usage. We and our third-party service providers also might use clear GIFs in HTML e-mails to our customers, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded. These can be blocked either by using a third-party application such as Ghostery or, in the case of emails, by changing your settings to prevent images from being downloaded (where your email client supports this functionality).
Third-Party Analytics
We use automated devices and applications, such as Google Analytics.
We also use services that enable us to better understand our users’ needs and optimize our platform and users’ experience. These services use cookies and other technologies to collect data on our users’ behavior (by tracking how much time users spend on which pages, which links users chose to click on, what users like or not) and their devices (in particular device's IP address (captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), preferred language used to display on our website). This information is stored in a pseudonymized user profile, and it will not be used to identify individual users or to match it with further data on an individual user.
9. HOW DO WE PROTECT YOUR PERSONAL INFORMATION
BRP makes commercially reasonable efforts to ensure that Personal Information collected from you is protected against loss and unauthorized access. This protection applies in relation to information stored in both electronic and hard copy format. Access to your Personal Information is restricted to individuals who have a business need consistent with the reason the information was provided. In addition, BRP employs generally accepted information security techniques, such as firewalls and access control procedures, to protect Personal Information against loss and unauthorized access.
Where we use service providers who might have access to your Personal Information, we require them to have privacy and security standards that are comparable to ours. We use contracts and other measures with our service providers to maintain the confidentiality and security of your Personal Information and to prevent it from being used for any other purpose.
International transfers of Personal Information
When sharing data with third parties in accordance with this Privacy Policy, your Personal Information may be transferred to countries where data protection laws may provide a lower standard of protection for your Personal Information than your jurisdiction of residence including the United States. We take great care in protecting your Personal Information and have put in place adequate mechanisms to protect it when it is transferred internationally. We will transfer your Personal Information in compliance with applicable data protection laws and will implement suitable safeguards to ensure that your Personal Information is adequately secured in accordance with all applicable laws. Please note that when your Personal Information is transferred outside your country of residence, it will be subject to the laws of the jurisdiction in which it is situated.
For Personal Information involving European Union citizens, transfers of Personal Information outside the European Union will be carefully reviewed prior to the transfer to ensure that they fall within the limits imposed by the General Data Protection Regulation 2016/679 (GDPR). This depends partly on the European Commission’s judgement as to the adequacy of the safeguards for Personal Information applicable in the receiving country and this may change over time. In these situations, when your Personal Information is disclosed to a third party in a receiving country that does not benefit from an adequacy decision, BRP incorporates Standard Contractual Clauses (SCCs) into contracts with these third parties. SCCs are written engagements between parties that are used as an appropriate ground for Personal Information transfers from the EU to third countries in order to provide appropriate data protection safeguards.
BRP incorporates the SCCs that are annexed to the European Commission’s Implementing Decision 2021/914 of 4 June 2021 for the transfer of Personal Data to third countries pursuant to GDPR, as well as the SCCs as amended by the International Data Transfer Addendum as issued by the UK Information Commissioner’s Office under S119A (1) Data Protection Act 2018.
Hereby, as of December 27th, 2022, these SCCs are incorporated to the contracts between BRP and all third parties who manage Personal Information on its behalf by reference.
10. LINKS TO THIRD-PARTY SITES
Our websites may offer links to third-party websites. You should be aware that operators of linked websites may also collect your Personal Information (including information generated through the use of cookies) when you link to their websites. BRP is not responsible for how such third parties collect, use, or disclose your Personal Information, so it is important to familiarize yourself with their privacy policies before providing them with your Personal Information.
11. PROTECTING THE PRIVACY OF CHILDREN
BRP’s websites are not targeted to or intended for use by children. We do not knowingly collect Personal Information from children under the age of 16. Children under 16 years of age should not register nor provide BRP with any personally identifiable information without the consent of a parent or legal guardian.
12. CHANGES TO THIS PRIVACY POLICY
BRP reserves the right to modify this Privacy Policy at any time without notice. The Privacy Policy posted via this website shall be deemed to be the Privacy Policy then in effect and the date at the top of the Privacy Policy will be updated to reflect the date of effectiveness. We recommend that you check this website from time to time to inform yourself of any changes in this Privacy Policy.
13. YOUR RIGHTS OVER YOUR PERSONAL INFORMATION
You can ask BRP what Personal Information we hold about you, and you can ask us to correct it if it is inaccurate.
You can ask us to stop sending you commercial communications. The simplest way to do so is to withdraw your consent, which you can do at any time, either by clicking the unsubscribe link at the end of any newsletter and commercial communications, or by emailing, writing or telephoning us using the contact information below. Please note however that when you do so, you are withdrawing your consent from receiving commercial communications from BRP, but you might still continue to receive commercial communications from the dealerships and distributors, who have their own independent consent management.
You can ask us to completely stop processing your Personal Information, and/or to erase it from our database. Please note that any request to stop the processing of your Personal Information or to be erased from our database will not be applicable when BRP has the obligation to communicate with you for health or safety related matter, such as safety recall or warranty matters regarding your BRP product(s).
For any of your requests, BRP may require relevant information or details in order to properly authenticate you.
You can help us maintain the accuracy of your Personal Information by notifying us of any changes to this information. In the event that you have any questions about BRP’s Privacy Policy or a complaint about our use of your Personal Information, including our use of service providers outside your jurisdiction of residence, you may contact our Privacy Officer in any of the following ways:
E-MAIL: privacyofficer@brp.com
MAIL: Bombardier Recreational Products Inc.
Attention: Legal Services
726, St-Joseph Street
Valcourt, Quebec
J0E 2L0
Canada
We are committed to working with you to obtain a fair resolution to any complaint or concern you may have about our use of your Personal Information. If, however, you believe that we have not been able to assist with your complaint or concern, you may have the right to lodge a complaint with the data protection authority in your country (if one exists in your country) or supervisory authority
We are committed to working with you to obtain a fair resolution to any complaint or concern you may have about our use of your Personal Information. If, however, you believe that we have not been able to assist with your complaint or concern, you may have the right to lodge a complaint with the data protection authority in your country (if one exists in your country) or supervisory authority.
Privacy Notice for California and Virginia Residents
This section supplements the information contained in our Privacy Policy and applies solely to clients, visitors, users, and others who reside in the State of California or in the State of Virginia (“consumers” or “you”). We adopted this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”), the California Privacy Rights Act (“CPRA”), other California privacy laws, as well as the Virginia Consumer Data Protection Act (“VCDPA”). Any terms defined in the CCPA, CPRA and VCDPA have the same meaning when used in this notice.
Information We Collect and Process
We process the following categories of Personal Information as indicated with a “yes” below:
Category | Whether we collect it or not? | Whether we disclosed it in the preceding 12 months or not? | Whether we disclosed it for a business purpose in the preceding 12 months or not? | Examples |
Category A – Identifiers | Yes | Yes | Yes | A real name, IP address, postal address, email address, social security number, driver’s license number or other similar identifiers.
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Category B – Personal Information as defined in the California Civil Code Section 1798.80(e) and/or any information that identifies, relates to, describes, or is capable of being associated with, a particular individual | Yes | Yes | Yes | A name, signature, contact information such as address and telephone number, employment, employment history, or financial information.
But we do not store any payment or credit card information. We only use payment information in connection with purchases of BRP products.
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Category C – Characteristics of Protected Classification under California, Virginia or federal law | Yes | Yes | Yes | We have access to age brackets and gender information on an aggregated basis through Google Analytics, which we use for statistical purposes.
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Category D - Commercial information | Yes | Yes | Yes | Transaction information, purchase history such as records of vehicles, product or services purchased or other purchasing or consuming histories or tendencies, financial details and payment information.
But we do not store any payment or credit card information. We only use payment information in connection with purchases of BRP products.
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Category E - Biometric information | No | No | No | Fingerprints and voiceprints.
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Category F - Internet or other electronic network activity information | Yes | Yes | Yes | Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems and advertisements.
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Category G - Geolocation data | Yes | Yes | Yes | Device location.
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Category H - Audio, electronic, visual and similar information | Yes | Yes | Yes | Service call recordings, images and 3D models created in connection with our business activities.
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Category I - Professional or employment-related information | Yes | Yes | No | Occupation, job title, or professional association membership information.
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Category J - Education information | Yes | Yes | No | Education level on the basis of postal codes.
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Category K - Inferences drawn from any of the Personal Information listed above | Yes | Yes | Yes | To create a profile or summary about, for example, an individual’s preferences and likelihood to purchase our vehicles, products or services.
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Categories A, B, C, D, F, G and K could constitute sensitive Personal Information, depending on the nature of the services and the context.
We collect the categories of Personal Information listed above from you and from other categories of sources, which sources are further detailed in the section “WHAT KIND OF PERSONAL INFORMATION DO WE COLLECT” of our Privacy Policy.
Use of Personal Information
We may use this Personal Information, including any sensitive Personal Information, to accomplish our business purposes and objectives, as further described in the section “HOW DO WE USE YOUR PERSONAL INFORMATION” of our Privacy Policy. We use certain type of Personal Information for profiling purposes.
Disclosing Personal Information
We may disclose the Personal Information we collected on you, as detailed above, to a limited range of third parties. We refer you to the section “HOW DO WE SHARE YOUR PERSONAL INFORMATION” of our Privacy Policy for more details.
Retention of Personal Information
We may retain this Personal Information, including any sensitive Personal Information, only for as long as necessary for the purpose for which we obtained it and for any other permitted ancillary purposes, as further described in the section “HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION” of the Privacy Policy.
Sales of Personal Information
We do not sell your Personal Information to third parties for their commercial purposes, except when you specifically allow us to do so.
In the preceding twelve (12) months, we have not sold any Personal Information. Please also note that any third parties who would purchase the Personal Information we hold, would be prohibited from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.
Your Rights and Choices
You have certain rights regarding your Personal Information, as described in the section “YOUR RIGHTS OVER YOUR PERSONAL INFORMATION” of our Privacy Policy. Under the CCPA, CPRA and VCDPA you also have the specific rights described below:
CCPA and CPRA:
(a) Right to request that we disclose to you:
(i) if we process your Personal Information and, where applicable, the categories of personal information we collected about you and the categories of sources from which we collected such information;
(ii) the specific pieces of personal information we collected about you;
(iii) the business or commercial purpose for collecting Personal Information about you; and
(iv) the categories of personal information about you that we shared or disclosed and the categories of third parties with whom we shared or to whom we disclosed such information in the preceding 12 months.
(b) Right to request that we delete (and direct our service providers to delete) Personal Information we collected from you subject to certain exceptions. We may deny your deletion request in certain circumstances, including for health or safety related matters, such as safety recall or warranty matters regarding your BRP product(s), in order to comply with a legal obligation or as otherwise provided for in the CCPA and CPRA.
(c) Right to not be discriminated against in pricing and services because you exercise any of your rights under the CCPA and CPRA. BRP does not offer financial incentives or price or service differences to consumers in exchange for the retention or sale of a consumer’s personal information.
(d) Right to direct us not to sell or share your Personal Information at any time (the “right to opt-out”).
(e) Right to direct us to limit our use and disclosure of sensitive personal information at any time, to that use which is necessary to perform the services or provide the goods.
(f) Right to request that we correct inaccurate Personal Information about you, taking into account the nature and the purposes of processing of the Personal Information.
(g) Right to not be retaliated against for exercising your rights.
VCDPA:
You have all the above rights, as well as the following:
(a) Right to obtain a copy of your Personal Information that you have previously provided us in a portable and, to the extent technically feasible, readily usable format, where the processing is carried out by automated means.
(b) Right to opt out of the processing of your Personal Information for purposes of targeted advertising, sale of your Personal Information or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
Exercising Your Rights
You can exercise your rights described above, by submitting a verifiable consumer request to us either:
· by email at privacyofficer@brp.com; or
· by calling us at 1-888-272-9222.
To exercise the right to opt-out and limit the use and disclosure of sensitive Personal Information, you may submit a request to us by clicking here: Do Not Sell or Share My Personal Information or here: Limit Use and Disclosure of Sensitive Personal Information. Once you make an opt-out request, we will wait at least 12 months before asking you to reauthorize Personal Information sales.
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may be required to submit proof of your identity for these requests to be processed as a verifiable consumer request and we may not be able to comply with your request if we are unable to confirm your identity or to connect the information you submit in your request with Personal Information in our possession.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. We will respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Appeal
You may appeal our refusal to take action on a request within a reasonable period of time after you have been notified of our decision. To exercise your right of appeal, you may send an email at privacyofficer@brp.com or call us at 1-888-272-9222.
Changes
We reserve the right to amend this Privacy Notice at our discretion and at any time. When we make changes to this Privacy Notice, we will post the updated Privacy Policy including this Privacy Notice on our websites and update the effective date identified at the top left of this Privacy Notice. Your continued use of our websites following the posting of changes constitutes your acceptance of such changes.