1. Introduction

This Privacy Policy explains the privacy practices of Enterprise Rent A Car Canada Limited. In this Privacy Policy, "Enterprise Canada", "we" and "our" collectively refer to the various divisions and affiliates of Enterprise Rent A Car Canada Limited. Our Privacy Policy may be amended from time to time, so we encourage you to periodically check our web site at www.enterprise.com/about/privacyPolicy/canadianofflinePolicy.html for the current version. Also, please be advised that our website also contains a separate privacy policy at www.enterprise.com/about/privacyPolicy.html which addresses privacy issues related to the use of that website. Printed copies of our current Privacy Policy are also available at all Enterprise Canada locations or by contacting one of our Privacy Officers.

2. Our Commitment to Your Privacy

Enterprise Canada has established this Privacy Policy to ensure that your personal information is protected and that all our practices and procedures comply with relevant personal information protection and privacy legislation. Accordingly, we adhere to the privacy principles set out below, which are based on the principles set out in Schedule 1 of the Personal Information Protection and Electronic Documents Act (Canada) and Provinces exempted under paragraph 26(2)(b) of the Personal Information Protection and Electronic Documents Act (Canada) where applicable. As used in our Privacy Policy, the term "personal information" means information about an identifiable individual, but does not include the name, title or business address or telephone number of an employee of an organization.

3. Accountability

Enterprise Canada is responsible for all personal information under our control. Accountability for our compliance with this Privacy Policy rests with our regional Privacy Officers and our Chief Privacy Officer, even though other individuals within Enterprise Canada may have responsibility for the day to day collection and processing of personal information.

Contact information for our Privacy Officer in your region is set out below:

Southwest Ontario

Enterprise Canada Privacy Officer
1790 Dundas Street Unit 8
London, Ontario N5W 3E5
(519) 451 5884
swontarioprivacyofficer@erac.com

Toronto, Ontario

Enterprise Canada Privacy Officer
7390 Woodbine Avenue, Suite 100
Markham, Ontario L3R 1A5
(905) 477 2199
torontoprivacyofficer@erac.com

Ottawa, Ontario

Enterprise Canada Privacy Officer
2300 Stevenage Drive
Ottawa, Ontario K1G 3W3
(613) 288 2998
ottawaprivacyofficer@erac.com

British Columbia

Enterprise Canada Privacy Officer
#9 - 19935 Langley Bypass
Surrey, British Columbia V3S 6K1
(604) 539 0866
britishcolumbiaprivacyofficer@erac.com

Alberta

Enterprise Canada Privacy Officer
119, 6227 2nd Street SE
Calgary, Alberta T2H 1J5
(403) 216 3490
albertaprivacyofficer@erac.com

Manitoba / Saskatchewan

Enterprise Canada Privacy Officer
554 Pembina Highway
Winnipeg, Manitoba R3M 2M4
(204) 478 7800
manitobasaskatewanprivacyofficer@erac.com

Quebec

Enterprise Canada Privacy Officer
5830 Cote De Liesse Ste 200
Mount Royal, Quebec H4T 1B1
(514) 735 3722
quebecprivacyofficer@erac.com

New Brunswick / Nova Scotia / Newfoundland / Prince Edwards Island

Enterprise Canada Privacy Officer
209 Aerotech Drive Unit #1
Enfield, Nova Scotia B2T 1K3
(902) 873 3300
nbnsnfpeiprivacyofficer@erac.com

You may also choose to contact our Chief Privacy Officer for Canada. Whose contact information is set out below:

Chief Privacy Officer Enterprise Canada
600 Corporate Park Drive
St. Louis, Missouri 63105
(800) 867 4943
canadaprivacyofficer@erac.com

Enterprise Canada is responsible for personal information in our possession or custody, including information that has been transferred to third parties for processing. We use contractual and other means to ensure that third parties, to whom we disclose personal information for processing, provide a comparable level of protection with respect to personal information in their possession or control.

4. Identifying Purposes

We will clearly identify and document the purposes for which we collect, use or disclose personal information at or before the time of collection.

Our purposes for collecting, using and disclosing your personal information will be limited to those which are related to providing you with our products and services and those purposes will be limited to what a reasonable person would consider appropriate in the circumstances.

If we plan to use personal information we have collected for a purpose not previously identified, we will identify and document the purpose and obtain your consent before such additional use. We will state the identified purposes in such a manner that an individual can reasonably understand how your personal information will be used or disclosed.

Enterprise Canada will use and disclose your personal information for the following purposes:

• to assist you with reserving, renting, purchasing and leasing motor vehicles, to provide you with our other products and services, to provide you with discounts, coupons and rebates, and to service your account with us and respond to your questions
• to provide you with information concerning car sales, ride-sharing, fleet services, and other information, opportunities and services that may be of interest to you
• to obtain payment for rental vehicles and services provided to our customers and in connection with the granting of credit, collection of accounts or in connection with providing credit history information to credit reporting agencies
• to assist us in providing our customers with better products and services (for example, we may contact you to assist us in evaluating the performance of our staff, to assess the quality of product and service received and to help us improve our facilities and services)
• to compile statistics and analysis about our customers use of our products and services, which statistics are only used internally to enable us to provide better customer service and products to you and other customers in the future

In addition to the above uses, we may disclose your personal information:

• to affiliates of Enterprise Canada, our agents and licensees, third parties such as insurance companies, and others
• to third party data processing and data storage facilities
• as necessary to comply with legal and professional requirements in connection with providing our customers with rental vehicles and related services or as we may believe in good faith that the law requires
• to persons engaged by Enterprise Canada to perform a credit check or persons involved in any efforts undertaken by Enterprise Canada to collect any outstanding debts or other fees which are due and owing by you to Enterprise Canada
• in special cases when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, customers or other users of our web sites, or anyone else who could be harmed by such activities

and for only such other reasons as a reasonable person would consider appropriate to provide Enterprise Canada customers with our products and services. Enterprise may disclose your personal information to third-party service providers located in the United States. These service providers are contractually required to maintain the confidentiality and security of your information. However, your information may be accessible to U.S. authorities in accordance with U.S. law.

Personal information you provide may also be combined or merged with information you provide online to www.enterprise.com as part of the standard business operations of Enterprise Canada and its parent companies and affiliates, provided; however, this Privacy Policy does not apply to information collected at www.enterprise.com. If the same information about you is gathered from www.enterprise.com and also from other sources with different privacy policies, Enterprise Canada's parent companies may elect, in their sole discretion, to treat such information in accordance with the privacy policy that least restricts our use and disclosure of such information.

5. Obtaining Consent

We will collect, use and disclose personal information only with the knowledge and consent of the individual, except where permitted by law.

We require informed consent, whether express or where in limited circumstances clearly allowed, by implied consent due to ongoing business or unsolicited disclosure, for the collection, use or disclosure of your personal information at the time of collection. In some circumstances, such as where we want to use personal information for a purpose that was not previously identified, we may have to seek your consent after your personal information has been collected but before our use for that purpose.

We will not, as a condition of supplying our products or services to you, require you to consent to the collection, use or disclosure of personal information beyond that which is absolutely necessary in order to supply the product or service.

In certain limited circumstances, as permitted or required by law, we may collect, use or disclose personal information without your knowledge or consent. Although the following list is not exhaustive, these circumstance include: (i) personal information which is publicly available as defined by the applicable regulations; (ii) circumstances where collection or use is clearly in your interest and consent cannot be obtained in a timely fashion; (iii) to investigate a breach of an agreement or a contravention of a law; (iv) to act in respect of an emergency that threatens the life, health or security of an individual; (v) for debt collection; or (vi) to comply with a subpoena, warrant or court order.

Please be aware that your personal information may be transferred to or stored on servers and processed outside the country of your residence, even if you reside in the United States of America.

By using our products and services you consent to the collection, use, retention and disclosure of your personal information as set out in this Privacy Policy. You may withdraw your consent with respect to any or all uses or disclosures of your personal information at any time (subject to legal or contractual restrictions) by sending written instructions to the Privacy Officer located in your region or the Chief Privacy Officer (an "Opt Out Notice") at the appropriate addresses set out above. Written instructions may be sent by means of electronic mail to the appropriate address set out above.

In the event you provide us with an Opt Out Notice, your information will be segregated and not disclosed or used in any manner about which you have objected. However, the personal information we have collected will be retained by us in accordance with our usual retention practices and procedures. You may at any time review such information as further set out below.

6. Limiting Collection

We will limit the amount and type of personal information collected to that which is necessary for our identified purposes and we will only collect personal information by fair and lawful means.

We collect the following types of personal information from our customers:

• names, addresses, telephone numbers, fax numbers, employer, e-mail addresses, driver's license numbers, expiration date and date of birth, credit card numbers, frequent flyer and other membership reward program information, and affiliations with companies or associations
• transactional information such as the locations, dates and times of your rental pick-up and return, your arrival airlines and flight numbers and the rental charges you incur, reason for renting the vehicle, and information collected from the use of computerized reservations systems utilized by travel agents to make reservations with us or our agents or licensees
• name of your insurer and the name of any mechanic or other trade people who may be working to repair your personal vehicle
• your creditworthiness and credit history from consumer reporting agencies in the event we perform a credit check
• name, age and drivers license information about any secondary or additional authorized driver of any vehicle rented from Enterprise Canada
• enrollment in any membership reward programs and similar programs we may offer to our customers from time to time

Accident and incident reports relating to your rentals from us and our licensees, and consumer reporting agencies and all other personally identifiable information you affirmatively provide to us pursuant to our rental agreement or any other form or agreement you may complete with us, our licensees or agents, or that you may volunteer to us, our licensees or agents pursuant to your use of our products and services, including, as a result of telephone calls to our reservations, assistance centers or as a result of telephone calls to or from vehicle repair shops or other third parties engaged by you with respect to your vehicle.

The collection, use and disclosure of personal information accumulated at www.enterprise.com is documented in the Privacy Policy located at that website at www.enterprise.com/about/privacyPolicy.html.

We may also gather personal information about you from other companies with which we maintain business relationships.

We endeavor not to collect any sensitive information (i.e., personal information specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or information about the sex life of an individual).

7. Limiting Use, Disclosure and Retention

Enterprise Canada does not use or disclose personal information for purposes other than those for which it was collected, except with the informed consent of the individual or as required by law. Enterprise Canada will retain personal information in active storage only for as long as is reasonably necessary for the fulfillment of those purposes, subject to legal requirements.

Except as otherwise provided in this Privacy Policy, we will not sell, exchange or rent any personally identifiable information about you that we obtain to or with companies or organizations not affiliated with us that would use the information to contact you about their own or others' products and services unless we have your permission. We may also provide information to marketing companies to assist us in offering products or services to you, to third party financial institutions and to business partners and third parties which assist us in providing products and services and/or handling transactions. Unless we have your permission or are required by law, we will only share the personal data you provide Enterprise Canada with other Enterprise Canada entities (our parent company and affiliated companies) and/or business partners who are acting on our behalf for the uses described in this Privacy Policy. Such Enterprise Canada entities and/or business partners, including those in the United States, Canada and/or any other countries, are governed by appropriate confidentiality obligations. Also, please be advised that in the event that Enterprise Canada should happen to sell all or substantially all of its assets, your personal information will likely be one of the transferred assets.

8. Accuracy

We will use our best efforts to ensure that personal information under our control that is used on an ongoing basis, including information that we disclose to third parties in accordance with this Privacy Policy, is as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used. In order to assist us in that regard, we urge you to provide us with updates regarding such information and to inform us of any errors affecting your personal information that we hold. Our customer's personal information is no longer updated after the rental period is complete unless required for the purpose of collecting outstanding charges on the rental.

9. Safeguards

We will protect personal information with safeguards appropriate to the sensitivity of the information. We employ appropriate safeguards to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification, regardless of the format in which the information is held. We make our employees and business partners aware of the importance of maintaining the confidentiality of personal information, and we will exercise appropriate care in the disposal or destruction of personal information to prevent unauthorized parties from gaining access to the information.

Our methods of protection include physical measures, organizational measures, and technological measures. Enterprise Canada restricts access to electronically stored customer information through passcode and employee identification number safeguards. Enterprise Canada uses a private computer system that is not shared with any other organization to which no other organization is provided access. Any paper files containing customer information are stored in areas of restricted access. Any personal information sent to and stored at our administrative office is subject to the same safeguards, and paper files are locked in a restricted access storage area.

10. Openness

We will make specific information about our policies readily available, except to the extent that it is confidential commercial information.

The information we will make available will include: (i) how to gain access to your personal information; (ii) the type of personal information held by us, including a general account of its use; (iii) general information concerning our Privacy Policy; (iv) what personal information is made available to third parties; and (v) how to contact our Privacy Officers.

Copies of the current version of our Privacy Policy are available in our retail stores and by contacting our Privacy Officers. Our Privacy Policy can also be viewed at our website at www.enterprise.com/about/privacyPolicy/canadianofflinePolicy.html.

11. Access

Upon written request addressed to one of our Privacy Officers, we will inform you of the existence, use and disclosure of your personal information. An individual can challenge the accuracy and completeness of his or her personal information under our control and have it amended as appropriate.

Should you want to review the personal information Enterprise Canada has on file about you, you may fill out a "Request for Individual Access to Personal Information" form available at any of our rental branches. Enterprise Canada commits to providing this information to you within 30 days of this request.

We will respond to an individual's written request within a reasonable time (generally within 30 days) and we will assist any individual who informs us that they need guidance in preparing a request. We may require an individual to provide sufficient information to permit us to provide an account of the existence, use and disclosure of personal information. While our response will typically be provided at no cost to the individual, depending on the nature of the request and the amount of information involved, we reserve the right to impose a reasonable cost. In these circumstances, we will inform the individual of the approximate cost to provide the response and proceed upon payment by the individual of the cost. Requested information will be provided or made available in a form that is understandable. Where possible, we will indicate the source of the information.

If you feel that the personal information we hold is inaccurate or incomplete, you are invited to advise our Privacy Officers of such inaccuracies and ask that we amend the personal information. Any such request should be in writing.

In providing an account of third parties to which we may have disclosed personal information about an individual, we will attempt to be as specific as possible. When it is not possible to provide a list of the organizations to which we have actually disclosed personal information, we will provide a list of organizations to which we may have disclosed the personal information.

If an individual successfully demonstrates an inaccuracy or incompleteness of his or her personal information under our control, we will amend the personal information as appropriate. If a challenge is not resolved to the satisfaction of the individual, we will record the substance of the unresolved challenge. Where appropriate, the amended information or the existence of the unresolved challenge, as the case may be, will be transmitted to third parties having access to the information in question.

In certain situations, we may refuse a request or not be able to provide access to all the personal information we hold about an individual. Exceptions to the access requirement will be limited and specific, as permitted or required by law. Where permitted, the reasons for denying access will be provided to the individual upon request. Although the following list is not exhaustive, exceptions may include: (i) information that contains references to other individuals or contains confidential commercial information, where such information cannot be severed from the record; (ii) information collected in the course of investigating a breach of an agreement or in the course of a formal dispute resolution process; and (iii) information that is subject to solicitor-client privilege.

12. Challenging Compliance

If you are not completely satisfied with our Privacy Policy and wish to submit comments or concerns regarding our privacy practices, we invite you to contact our Privacy Officers. We will thoroughly investigate all written complaints addressed to our Privacy Officers. If we find a written complaint to be justified, we will take all appropriate measures, including, if necessary, amending our policies and practices.

If for any reason you are not satisfied with the results of our investigation of and responses to your complaint, you may file a complaint with the Office of the Federal Privacy Commissioner, 112 Kent Street, Ottawa, Ontario, K1A 1H3, Telephone: 1-800-282-1376.