GENERAL PRIVACY NOTICE CANADA


Automobili Lamborghini S.p.A. (“Lamborghini”, “us,” “we,” and “our,” as the context may require) is committed to protecting the privacy of your personal information. This Automobili Lamborghini S.p.A. Canada Privacy Policy (the “Policy”) explains Lamborghini’s privacy practices with respect to Canadians’ personal information, as well as the choices you can make about the way we collect, use and disclose your personal information, so that you can better understand how we handle the personal information we control.
Definitions of “personal information” may vary from one jurisdiction to another but generally, “personal information” means any information about an identifiable individual, meaning there is a serious possibility that an individual could be identified through the use of that information, alone or in combination with other information.
If you are unsure if or how this Policy applies to you or have questions or concerns about this Policy, or our personal information handling practices, please contact us at the address specified in the “How to Contact Us” section.

Key Highlights

We appreciate that your time is valuable. This section of the Policy contains a brief overview of certain key points related to our collection, use and disclosure of your personal information. However, we recommend that you read the Policy in full, as it contains additional important details about our processing of personal information.

What personal information we collect and how: The personal information we may collect about you and how we obtain it varies depending on the nature of our relationship with you and how you interact with us. For example, we may collect your personal information directly from you when you visit or use our websites or apps or our dealers’ web pages, register for or attend special events, complete our surveys, sign up to receive our marketing communications, interact with us, request, express interest in, purchase, use and/or receive our products or services or submit a warranty claim. We may also obtain personal information about you indirectly, including from our dealers who collect personal information from you and then disclose it to us, from our affiliates, and from our partners in joint marketing activities. We may collect your personal information via call recording when you communicate with us by telephone through our Contact Center, and by using cookies and other tracking technologies as described in our Cookie Policy. We and/or our affiliates may also collect information concerning a Lamborghini-branded vehicle that you purchase and your contact data from motor vehicle registration authorities in the territory in which the dealer who sold you the vehicle operates.

Generally, the personal information we may collect falls into the following categories, not all of which may apply to you: (i) identifiers and contact information, such as your full name, salutation, country of residence, home and postal address, telephone or mobile number, email address, occupation and signature; (ii) proof of advance payment for a vehicle; (iii) information concerning your vehicle purchase, use and servicing, including the make, model, configuration, options/customizations and vehicle identification number of any Lamborghini-branded vehicle that you own, your license plate number, and the software and hardware version and serial numbers of the vehicle’s hardware; (iv) information relating to your use of the Connected Services (as defined below) and related mobile applications; (v) information relating to your individual preferences, hobbies and interests, including as related to our products, services, events and communications; (vi) information concerning any warranty claims that you submit; (vii) information about your online activities, as described in our Cookie Policy; and (viii) your survey responses and feedback.

Why we collect personal information and how we use it: Our reasons for collecting your personal information and how we use it will vary depending on the nature of our relationship with you but, generally, we only use and share personal information for the purposes for which it was collected, unless we’re legally allowed or required to use it for another purpose. For example, subject to obtaining your consent if required by applicable law, we may collect and use your personal information to establish, maintain and manage our relationship with you, to provide you with the products, information, services and assistance that you request, to enable you to create an account, to administer (or assist our dealers with the administration of) the purchase or servicing of your vehicle or warranty, to communicate with you, to obtain your feedback, to conduct recall campaigns, to improve our products (and their safety features) and our services on an ongoing basis, to maintain, provide and improve the websites and apps that we own and operate, to conduct research activities, to build and maintain a customer profile of you, to send or serve you sales, advertising, promotional and marketing materials (which may be personalized or targeted), to host events, to generate aggregate and/or anonymous data, to maintain appropriate business records, to protect, defend and enforce our legal rights and contracts, and to comply with the law and other processes and requirements.

How we share personal information: We may disclose your personal information to our dealers and/or to third party vendors who provide certain products and services that you purchase through us (such as Wi-Fi hotspot or roadside assistance services), who may each use this information for their own business purposes. We may share your personal information with our affiliates and with our technical support, customer service, marketing, payment processing, customer relationship management (CRM) software, satellite radio, data storage and processing and legal, accounting and other professional service providers that assist us in fulfilling the purposes for which we collected your personal information. We may also disclose your personal information to a third party in the event of a business transaction involving us or our affiliates, such as a merger or reorganization of our business, or where otherwise permitted or required by applicable law.

Cross-Border Transfers: We and our affiliates and service providers may transfer, communicate, process and store your personal information outside of Canada (and, if you are located in Quebec, outside of Quebec). Consequently, your personal information may be accessible to foreign courts, law enforcement and national security authorities.

For more details about the personal information we collect, how we collect it, and how we use and share it, please read the corresponding sections below.

Personal Information We Collect

General Information We Collect

We may collect the following personal information in the following circumstances:

  • Information that we collect from you when you visit the websites and apps that we own and operate, including www.lamborghini.com (throughout this Policy, we refer to these websites, along with any other websites we may own and operate – such as the Lamborghini car configurator (view privacy policy here) and dealer locator sites (view privacy policy here) – as the “sites”), as specified in each site privacy policy. For more information about our use of cookies and other tracking technologies on www.lamborghini.com, please see here;
  • Information that you submit to us through the sites, including through any “Contact Us”, “Contact a Dealer” or similar features, or when you use the chatbot feature, including your first and last name, country of residence, the vehicle identification number (“VIN”) of any Lamborghini-branded vehicles that you own, and your contact information (such as your email address and/or phone number); 
  • Information that you submit through our dealers’ web pages, including your first and last name, country of residence, the VIN of any Lamborghini-branded vehicles that you own, and your contact information (such as your email address and/or phone number);
  • Information that you submit to us or that is collected via call recording when you communicate with us by telephone through our Contact Center, including your first and last name, country of residence, home address, the VIN of any Lamborghini-branded vehicles that you own, your contact information (such as your email address and/or phone number), recordings of your voice, and any other personal information that you share during our conversation;
  • Information that you submit to us when you sign up for our newsletter or other marketing communications, including your first and last name and email address;
  • Information that you or others provide to us when you sign up for, register for, and/or participate in any event that we sponsor or co-sponsor, including your first and last name, country of residence, and contact information (such as your email address and/or phone number);
  • Information that you provide when you complete one of our surveys or otherwise provide us with feedback, including your first and last name, country of residence, make/model of any Lamborghini-branded vehicles you own, your contact information (such as your email address and/or phone number), and your survey responses or feedback (including any opinions, preferences, views, experiences or other personal information they contain);
  • Information that is provided to us in connection with your interest in, purchase of, or servicing of a Lamborghini-branded vehicle from or at an authorized Lamborghini dealer, including your first and last name, country of residence, the VIN of any Lamborghini-branded vehicles that you own, information generated by those vehicles (such as tire pressure, consumable levels), your contact information (such as your email address and/or phone number), and your preferences (such as your products and services of interest, and expressed hobbies and interests); and
  • Information that you or others provide to us when you use Lamborghini assistance services such as Lamborghini roadside assistance, including your first and last name, country of residence, the VIN of any Lamborghini-branded vehicles that you own, and your contact information (such as your email address and/or phone number).

We may also collect, use and disclose certain personal information that is collected from you by our authorized dealers, including as follows:

  • Information that you provide to our dealers in person when creating a customer account, including your first and last name, country of residence, the VIN of any Lamborghini-branded vehicles that you purchase or own, your contact information (including your email address, phone number, salutation and/or home or mailing address), your occupation, and your communications preferences; 
  • Information that you provide in connection with your interest in, purchase of, or servicing of a Lamborghini-branded vehicle from or at an authorized Lamborghini dealer, including your full name, postal and email addresses, telephone and mobile numbers, signature, proof of advance payment for a vehicle, the model, configuration and vehicle identification number of the vehicle you purchase, your license plate number, your preferences and selections with respect to the vehicle you purchase (such as external and internal colours and other options and customizations), and your purchase/order history; and
  • Information that you provide in connection with a warranty claim that you submit through an authorized Lamborghini dealer, including your first and last name, country of residence, the VIN of any Lamborghini-branded vehicles that you purchase, your contact information (including your email address and phone number), and the nature of your claim.

Information We Collect Through Connected Services and Mobile Applications

Certain of our vehicles include hardware and software that provide connected car services (“Connected Services”). If you use our Connected Services, you should also refer to the Connected Services Privacy Policy for your vehicle, which can be accessed through your vehicle’s Connected Services dashboard.

The Connected Services Privacy Policy applicable to your vehicle will provide information about how we collect, use, and share information collected through Connected Services.

In addition, we offer a mobile application that works with Connected Services called the Unica App. We may from time to time offer other mobile applications that provide our customers and others with additional functionality and features, such as our Track & Play App. These and any other such mobile applications will be subject to their own privacy policies and additional privacy notices included within the application, which you should review in addition to this Policy. For example, you may review the Privacy Policy that applies to the Unica App here.

If your vehicle is equipped with online “over the air” system update capability, we will also collect software and hardware version and serial numbers of vehicle hardware and use this information to provide online system updates.

How We Collect Personal Information

Directly from You: We may collect personal information directly from you when you interact directly with Lamborghini. Depending on the circumstance, we may collect this personal information using forms and chatbots on the sites, surveys and at our events. We may record inbound and outbound calls to or from our Contact Center for quality assurance purposes, training, and to manage our relationship with you. We may also collect your personal information using cookies and other tracking technologies, as described in our Cookie Policy.

From our Dealers: As noted above, we may also collect and use some of your personal information that you provide to our authorized dealers. For example, you may provide your personal information to a dealer when visiting a dealership and creating a customer account, when purchasing a vehicle, when receiving after-sales service or when submitting a warranty claim. The personal information that you provide to the dealer is then shared with us (and/or our affiliates) through our customer relationship management system, known as LamborghiniKEY. 

However, please note that this Policy only applies to personal information that is collected by dealers in the circumstances described above and that is shared with us via LamborghiniKEY. Our dealers may collect, use, and share your personal information in other ways, and we do not and cannot control their collection, use, and sharing of your personal information in these cases. For more information about a dealer’s privacy practices, you should review any additional privacy notice or policy posted on the applicable dealer’s website or ask that dealer for more information. 

From Authorities: We and/or our affiliates may also collect information concerning a Lamborghini-branded vehicle that you purchase (including the vehicle identification number and license plate number) and your contact data from motor vehicle registration authorities in the territory in which the dealer who sold you the vehicle operates.

From other Third Parties: We may also obtain your personal information from third parties who help us operate our business. For example, we may conduct joint marketing activities (such as contests, sweepstakes or social media campaigns) through which we may obtain your name, address and email address from our third party partners in such activities. Lamborghini and each of these third-party organizations have their own privacy policies and procedures, and it is recommended that you read and understand both. Lamborghini is not responsible for such third parties' compliance with applicable privacy laws. Any questions concerning their privacy policies and procedures (including opting out of their marketing communications) should be addressed directly to such third parties.

Why We Collect Personal Information and How We Use It

To the extent permitted by applicable law, Lamborghini collects and uses personal information to enable us to develop, manage and maintain our operations and business, including for example:

  • to establish, maintain and manage our relationship with you so that we may provide you with the products, information, assistance or services that have been purchased or requested by you (including, for example, responding to your questions or requests for products, information or services, arranging for the manufacturing and delivery of the Lamborghini-branded vehicle that you purchase, and communicating with you about the customization, production, shipment and delivery of the Lamborghini-branded vehicle that you purchase);
  • regarding Connected Services:
    - to enable you to create an account with Lamborghini which will enable you to register, subscribe and/or use various services provided by Lamborghini or third parties;
    - to enable the provision of such services to you; and
    - for other purposes described in this Policy;
  • to be able to review the products and services that we provide to you and your feedback so that we may:
    - understand your requirements for our products and services;
    - understand your preferences and needs; and
    - work to improve our products and services;
  • to administer or assist our dealers with the administration of your vehicle warranty, purchase or servicing, including to ensure continuity of service if a dealer’s rights are terminated or set to expire and to assess any warranty claims and, if applicable, provide or arrange for repair or replacement of your vehicle’s parts;
  • to provide you with information about your vehicle (including product campaigns and recalls);
  • to send you sales, advertising, promotional and marketing materials, including those that we believe may be of interest to or tailored to you based on your purchase and service history, interactions with us, expressed hobbies or interests and/or vehicle use, including, for example, materials about our vehicles, products or services, events and promotional or loyalty offers;
  • to conduct market research and customer satisfaction surveys;
  • to host special events;
  • to provide, maintain and improve our sites and mobile applications;
  • to build and maintain a customer profile of you to be used for any of the above purposes;
  • to protect Lamborghini against error, fraud, theft, and damage to our goods and property;
  • to enable us to comply with applicable laws or regulatory, auditing, risk management, security and accounting processes and requirements;
  • to protect, defend and enforce our and our affiliates’ legal rights and contracts;
  • to maintain appropriate business records;
  • for any other purposes described in this Policy; 
  • for any other reasonable purpose to which you consent at or before the time we collect your applicable personal information; and
  • for such other purposes as are permitted by applicable law.

How We Share Personal Information

We may share your personal information in the following circumstances: 

Affiliates: We may share any of your personal information with our affiliates (including Lamborghini Canada, a division of Audi Canada, Inc.), who may collect and use such information in order to manage customer and prospect relationships, provide us with administrative and accounting services, and for other business purposes consistent with those listed above. Lamborghini Canada and other divisions of Audi Canada, Inc. may also collect, use and disclose your personal information on their own behalf for other purposes (including, for example, when you agree to receive their marketing materials, market research and other surveys, and other personalized materials), and we do not and cannot control their collection, use and disclosure of your personal information in these cases. For more information about Audi Canada, Inc.’s privacy practices, you should review their privacy policy.

Service Providers: We may share your personal information with our suppliers, contractors and professional advisors that perform the following services for us:

  • (i) website hosting, network, technical support and other information technology services, who may use technical, log and access data for the purposes of providing technical support and analyzing potential malfunctioning of the sites;
  • (ii) customer service, who may use identification data for the purposes of managing your requests and providing you with the support requested; 
  • (iii) marketing services, who may use contact data for the purposes of serving you marketing and communication material;
  • (iv) legal, accounting and other professional services, who may use identification data for the purposes of providing their professional services;
  • (v) customer relationship management software, who may store your data for the purposes of enabling us to manage our relationship with you; and
  • (vi) data storage and processing services, who may store your data for the purposes of providing us storage services.

For more information about the specific service providers with whom personal information is shared, please contact us using the contact information set out below.

Dealers: If you fill out the Contact A Dealer form on our sites, we may disclose your personal information (including your full name, salutation, country of residence, home and postal address, telephone or mobile number, email address, occupation and signature) via LamborghiniKEY to the dealer(s) you selected, who may use it to contact and communicate with you, provide you with the information you have requested, send you information about products or services that may be of interest to you, and otherwise establish a relationship with you. If you make a change to your account information via the Unica App, we may share your new or updated personal information with any dealer(s) with whom you have a relationship.

Third Party Vendors: When you request or purchase certain products and services from a third party vendor through us (e.g. Wi-Fi hotspot services or roadside assistance services), we may disclose your personal information (including your name, email address, and the VIN of your Lamborghini-branded vehicle) to that vendor in order for that vendor to: (i) create and manage its relationship with you; and (ii) provide you with the products and/or services that you seek.

Legal Matters: We may also disclose your personal information as required or permitted by law, for example, in connection with an investigation, litigation, subpoena, summons, warrant or other request from a public authority, and to appropriate authorities to protect our rights, your safety or the safety of others, investigate fraud, or respond to a law enforcement request.

Transactions: Your personal information may be disclosed or transferred to another party during the course of (i) the grant of a security interest in Lamborghini or Audi Canada, Inc.’s assets, or (ii) completion of the sale of all or a part of Lamborghini or Audi Canada, Inc. (for example, an asset or share sale, or some other form of business combination, merger or joint venture); provided, however, that such party is bound by appropriate agreements or obligations if and as required by applicable law.

Internally: Your personal information will be accessible internally to our personnel who need it for their job duties, including members of our information technology (IT) and security, legal and compliance, management and administration, finance and accounting, marketing and sales, and customer care and support teams. 

International or Interprovincial Transfers of Personal Information

We and our affiliates and service providers may transfer, communicate, process and store your personal information outside of Canada (and, if you are located in Quebec, outside of Quebec). Consequently, your personal information may be accessible to foreign courts, law enforcement and national security authorities. For example, we could be obliged to respond to a subpoena or other mechanism that would give law enforcement officials in that other jurisdiction access to your personal information.

If you are located in Alberta, you may contact our Data Protection Officer at dpo@lamborghini.com to (i) obtain access to written information about our policies and practices with respect to service providers outside Canada, or (ii) ask a question about the collection, use, disclosure or storage of personal information by service providers outside Canada for or on behalf of us.

Collection of Personal Information from Minors

We do not seek to obtain, nor do we wish to receive, personal information directly from minors; however, we cannot always determine the age of individuals with whom we interact (e.g. individuals who access and use our sites). If a minor (as defined by applicable law) provides us with his or her personal information without the consent of the parent, guardian, or person exercising parental authority, please contact us at one of the coordinates mentioned in the “How to Contact Us” section. We will also endeavour to delete the minor’s personal information if we have not obtained appropriate consent.

De-Identified and Anonymized Information

To the extent that we are allowed to do so under applicable laws, we may de-identify or anonymize your personal information and use and disclose such de-identified or anonymized information for any purpose permitted by applicable law (including, for example, for research and development purposes, data analytics and assembling and analyzing statistics) without further notice to you.

Our Use of Commercial Electronic Messages

We will only send you commercial electronic messages if we have your implied or express consent to do so or as otherwise permitted or required by applicable law. For example, to the extent permitted by applicable law, we may send email, text or other electronic messages to you: (i) if you have an existing vehicle warranty, purchase a service directly from us, or have some other form of existing business relationship with us; or (ii) if you have asked for or otherwise expressly agreed to receive such electronic messages from us, such as by signing up for our newsletter or by agreeing to receive marketing communications from Lamborghini in the context of one of your interactions with a dealer. You can withdraw your consent or request to stop receiving such messages at any time either by using the unsubscribe mechanism within the body of any such message or by contacting us at one of the coordinates mentioned in the “How to Contact Us” section. 

Our Use of Cookies and Similar Technologies

Like many organizations, we and our affiliates, partners and third-party service providers use cookies and similar technologies, including web beacons, pixels, embedded scripts and e-tags (together referred to as “cookies”), and the information collected using such cookies, for a variety of reasons, including: to provide users with a better and more efficient user experience, to provide marketing and other content that is more relevant to the user’s interests, preferences and presumed needs, to provide users with our services, our sites and our apps, to analyze how users use our sites, apps and services, and to enhance our site, app and services performance.

To understand how, when and why we and our affiliates, partners and third-party services providers use cookies, the information they collect, please review our Cookie Policy.

You can control the cookies used when you visit our sites and apps by modifying the relevant settings in your browser or on your device. Through those settings, you should also be able to delete cookies that have already been placed on your device. For information and instructions on how to change your cookie settings on different browsers and mobile devices, see our Cookie Policy. You can also modify your selections regarding the setting of cookies using the cookie banner on each site.

Security of Personal Information

We maintain physical, organizational, contractual and technological measures and follow generally accepted industry standards designed to preserve and safeguard the confidentiality and integrity of your personal information against unauthorized access, use, disclosure, alteration, destruction or loss.

Despite these measures, we can’t guarantee that our safeguards will always be effective. For example, hardware or software failure, and other events such as a ransomware attack may compromise the security of your personal information.

If you have reason to believe that your interaction with us is no longer secure or if you feel that the security of any personal information that you provided to us or that is under our control has been compromised, please advise us using the contact information set out below.

Roles & Responsibilities of our Personnel

Our Data Protection Officer has overall responsibility for our compliance with privacy laws and the day-to-day implementation and improvement of our privacy program, including providing training to employees, publishing policies and procedures, responding to complaints and potential violations of this Policy or laws, and responding to rights requests. Our Data Protection Officer is responsible for implementing its information security program and controls. Our Data Protection Officer serves as Lamborghini’s “person in charge of the protection of personal information” within the meaning of Quebec’s privacy law, and can be contacted at dpo@lamborghini.com.

All of our employees are responsible for protecting the confidentiality of personal information they handle, following our security measures and policies and procedures for handling personal information, avoiding unauthorized access, use or disclosure of personal information, helping answer rights requests, and reporting security incidents.

Retention, Keeping & Destruction of Personal Information

We will retain your personal information for as long as necessary to fulfil each of the purposes for which it was collected, or as otherwise permitted or required by law. For example, we will retain your personal information for the period of time required to provide you with our products and services, to comply with applicable legal, contractual, tax or accounting requirements, or to defend ourselves from possible legal actions. When this retention period expires, your personal information will either be anonymized or destroyed in accordance with applicable law. If you would like more information on how long we retain your personal information, please contact us using the contact information set out below.

Where personal information is no longer needed, we either anonymize it (in which case we may further retain and use the anonymized data) or securely destroy it in accordance with applicable laws. Personal information printed on paper is destroyed by shredding, and personal information stored by electronic means is deleted using a technical method that cannot be reproduced.

Your Rights

Your rights relative to your personal information may vary depending on where you live. When contacting us to exercise your rights under applicable laws, please note that we may request specific information from you to enable us to confirm your identity and right to access or correct, as well as to search for and provide you with the personal information that we hold about you. We may charge you a reasonable fee to access your personal information; however, we will advise you of any fee in advance. If you require assistance in preparing your request, please contact us using the contact information set out below.

You can request to exercise the rights listed below by submitting a request in writing using the contact information set out below under “How to Contact Us”.

Withdrawing Your Consent: You may have the right to change or withdraw your consent to the further collection, disclosure or use of your personal information, subject to reasonable notice and to certain restrictions and limitations such as legal or contractual obligations. Please note that in some cases, the withdrawal of consent may render us unable to continue to provide you with products or services where the collection, use or disclosure of your personal information is necessary to provide the product or service.

Accessing Your Personal Information: You may have the right to request to access your personal information that we hold. Please note that your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, your personal information may have been destroyed, erased or made anonymous. If you are in Quebec, you may also have the right to request a portable copy of your personal information.

Correcting Your Personal Information: You may have the right to request that any incomplete or inaccurate personal information we hold about you be corrected, subject to certain limitations. That said, it is important that the personal information contained in our records is both accurate and current, so if your personal information happens to change during the course of our relationship, please keep us informed of such changes.

How to Contact Us 

All complaints or requests for information related to this Policy or to our collection, use, disclosure, protection or other handling of personal information, or requests to exercise your rights as set out above, should be submitted by contacting the Data Protection Officer:

  • Online, via the dedicated contact form at https://www.lamborghini.com/es-en/contacto
  • By mail to:
    Automobili Lamborghini S.p.A.
    c/o Audi Canada, Inc
    777 Bayly Street West
    Ajax, ON L1S 7G7;
  • By phone call to 905-428-4610; or
  • By email at dpo@lamborghini.com.

If you have any questions regarding a dealer’s use of your personal information, you should visit the applicable dealer’s website or contact the dealer directly.

Complaint Process

Our process for dealing with complaints regarding the protection of personal information generally includes:

  • Acknowledging and noting the date of receipt;
  • Confirming the complainant’s identity and collecting details about the complaint and any relevant documents;
  • Considering applicable laws;
  • Conducting an investigation; and
  • Documenting and communicating to the complainant the outcome of the investigation, including any corrective measures (where justified).

Interpretation of This Policy

This Policy includes examples but is not intended to be restricted in its application to such examples; therefore, where the word "including" is used, it shall mean "including without limitation".

This Policy does not create or confer upon any individual any rights or impose upon Lamborghini any rights or obligations outside of, or in addition to, any rights or obligations imposed by Canada's federal and provincial privacy laws, as applicable. Should there be, in a specific case, any inconsistency between this Policy and Canada's federal and provincial privacy laws, as applicable, this Policy shall be interpreted, in respect of that case, to give effect to, and comply with, such privacy laws.

Changes to this Policy

We may make changes to this Policy from time to time. Accordingly, we encourage you to refer back to it on a regular basis. To the extent permitted by applicable law, your continued use of the sites after we make changes will constitute your deemed acceptance of these terms.