In the course of conducting our information services and technology business worldwide, **Euro Auto Auctions** collects and processes personally identifiable information of our clients, shareholders, employees, suppliers, business partners, website visitors, and other persons (Personal Data). Maintaining the integrity and confidentiality of Personal Data and handling it correctly is central to the way we conduct our business activities. This policy describes how we handle Personal Data.

Personal Data is information that can be used directly or indirectly to identify a living individual. Personal Data may include sensitive categories of information, such as information that reveals racial or ethnic origin, political opinions, religious beliefs, trade union membership, health, or sexual orientation (Sensitive Personal Data).

This policy applies to **Euro Auto Auctions** and its subsidiaries, and is effective as of June 1, 2024. All employees will be required to abide by this policy.

This policy is designed to protect Personal Data under applicable law as it currently exists. However, **Euro Auto Auctions** realizes that this policy cannot address every potential issue and circumstance. Therefore, we acknowledge that this policy is subject in all respects to applicable local legal and regulatory requirements and existing agreements and confirm that we will comply with such requirements and existing agreements.

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**Privacy Principles**

We will observe the privacy principles described below of Notice, Choice/Fair Processing, Access, Security/Integrity, Onward Transfer, and Enforcement/Compliance in processing Personal Data.

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**Notice**

When we collect and process Personal Data about individuals, we will make certain information available to those individuals on a reasonable and timely basis. This information will include what Personal Data is being collected, who is collecting it, how and for what purposes it is being collected, how it is being used, and to whom it will be disclosed.

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**Choice/Fair Processing**

We will process Personal Data only with consent or when such processing is permitted by applicable law. If we need to process Sensitive Personal Data, we will obtain explicit consent for such processing, unless such processing is permitted by applicable law.

We will not process Personal Data in a manner incompatible with the purposes for which it was originally collected unless later authorized by the affected individuals or allowed by law; we will take reasonable steps to ensure that such data is accurate, adequate, relevant, and not excessive in relation to such purposes; and we will not keep such data longer than is necessary for such purposes.

We will enable individuals to choose whether their Personal Data can be disclosed to a third party for direct marketing purposes.

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**Access**

We will allow individuals reasonable access to their Personal Data to verify, correct or delete their data, where inaccurate. We will also provide a means for individuals to exercise all other legal rights that they may have in relation to their Personal Data.

Personal Data will be accessible and processed only by (i) **Euro Auto Auctions** employees, suppliers, third-party sellers, business partners, and others who require access for the performance of their obligations to **Euro Auto Auctions**; (ii) any person granted access by the individual to whom Personal Data pertains; and (iii) those otherwise authorized by law or court order.

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**Security/Integrity**

We will take reasonable security procedures through appropriate technical and organizational measures to protect against unauthorized or unlawful access or processing, disclosure, alteration, destruction, or accidental loss of Personal Data.

We will utilize reasonable means to keep Personal Data accurate, complete, and current in order to protect the quality and integrity of Personal Data. However, we rely on individuals to provide all relevant information and to advise us of any changes to their Personal Data to ensure that it remains accurate, complete, and current.

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**Onward Transfer**

When we transfer Personal Data within **Euro Auto Auctions** or to third parties (including our suppliers and business partners), we will observe the privacy principles of Notice and Choice (described above), and we will require all the recipients of such data to provide at least the same level of protection for such data as specified by the standards stated in this policy.

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**Enforcement/Compliance**

We will follow internal processes for handling complaints regarding our management of Personal Data.

We will demonstrate our compliance with this policy by: publishing this policy conspicuously so that it is accessible to all interested persons; appointing and maintaining a Privacy Officer with responsibility for developing and implementing a privacy program; implementing procedures to execute this policy in the conduct of our business, including training our employees in the use of such procedures and disciplining employees for failure to comply with this policy and its procedures; at least annually, reviewing this policy to ensure that it continues to comply with prevailing privacy standards, current applicable law, and regulations and existing agreements. This policy applies to Personal Data collected through **Euro Auto Auctions** websites (www.euroautoauctions.ca). As a convenience to our website visitors, we sometimes provide links to other websites. These linked sites are not under the control of **Euro Auto Auctions**, and as such, we are not responsible for their content.

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**Updating the Policy**

Changes in legislation and/or our business activities may require that this policy be updated from time to time.