Aston Auto Innovation Privacy Policy

Aston Auto Innovation ("Aston Auto Innovation," "Aston Auto," "Aston," "Company," "we," "us," or "our") respects the privacy of its customers, prospective customers and website visitors and is committed to handling personal information in accordance with applicable Canadian law.

This Privacy Policy explains how Aston Auto Innovation may collect, use, disclose, store, process, retain and protect personal information in connection with our dealership operations, websites, advertisements, financing activities, vehicle transactions, communications and other services.

This Policy applies when an individual:

• visits or interacts with our website;
• submits an online inquiry;
• contacts us through telephone, email, SMS, WhatsApp, social media or another communication platform;
• visits our dealership or vehicle lot;
• requests information concerning a vehicle;
• schedules or undertakes a test drive;
• purchases or proposes to purchase a vehicle;
• trades or proposes to trade a vehicle;
• sells a vehicle to Aston Auto Innovation;
• requests financing;
• submits a credit or financing application;
• makes a payment or deposit;
• purchases a warranty or other product;
• communicates with our employees or representatives; or
• otherwise conducts or proposes to conduct business with Aston Auto Innovation.

By voluntarily providing personal information to Aston Auto Innovation, you acknowledge the practices described in this Privacy Policy.

Where applicable law requires separate or express consent for a particular collection, use or disclosure, Aston Auto Innovation will obtain such consent separately.

Nothing in this Privacy Policy is intended to waive, restrict or exclude any right or obligation that cannot lawfully be waived, restricted or excluded.

Aston Auto Innovation intends to comply with applicable Canadian privacy legislation governing its activities, including the Personal Information Protection and Electronic Documents Act ("PIPEDA"), where applicable, together with applicable Ontario laws and regulatory requirements.

Our commercial electronic communications are also intended to comply with applicable requirements of Canada's Anti-Spam Legislation (“CASL”).

Our obligations may vary depending upon:

• the nature of the transaction;
• the type of information involved;
• the location of the individual;
• the service requested; and
• the legal or regulatory requirements applicable at the relevant time.

Where applicable legislation imposes requirements that differ from this Privacy Policy, the applicable legislation will govern to the extent of the inconsistency.

Aston Auto Innovation is responsible for personal information under its control to the extent required by applicable law.

Aston may use employees, independent contractors, software providers, payment processors, lenders, financial institutions, hosting providers and other service providers in operating its business.

The involvement of a service provider does not mean that Aston Auto Innovation owns or controls that provider.

Where required by applicable privacy legislation, Aston will take reasonable measures appropriate to the circumstances to require service providers processing personal information on Aston's behalf to maintain appropriate safeguards.

Personal information means information about an identifiable individual.

Depending on your interactions with Aston Auto Innovation, we may collect information including:

Identification Information

• name;
• address;
• email address;
• telephone number;
• date of birth;
• driver's licence information;
• identification numbers; and
• other information reasonably necessary to identify or verify an individual.

Vehicle Information

• vehicle make, model and year;
• VIN;
• licence plate;
• registration information;
• ownership information;
• odometer information;
• vehicle history;
• accident history;
• lien information;
• trade-in information;
• vehicle photographs;
• inspection information; and
• information concerning the condition of a vehicle.

Transaction Information

• purchase information;
• sale information;
• trade-in value;
• deposits;
• payment information;
• financing information;
• warranty information;
• contracts;
• bills of sale;
• invoices;
• refunds;
• chargebacks; and
• other transaction records.

Financing and Credit Information

Where financing is requested, Aston Auto Innovation may collect information including:

• employment information;
• employer name and contact information;
• length of employment;
• income;
• financial obligations;
• housing status;
• banking information;
• credit information;
• identification information;
• date of birth;
• previous addresses;
• information requested by prospective lenders; and
• other information reasonably necessary to facilitate a financing application.

Communication Information

We may retain communications made through:

• telephone;
• email;
• text message;
• WhatsApp;
• website forms;
• online chat;
• Facebook;
• Instagram;
• TikTok;
• marketplace websites;
• advertising platforms; and
• other communication services.

Technical and Website Information

Our website and technology providers may collect:

• IP addresses;
• browser information;
• device information;
• referring websites;
• pages visited;
• interaction data;
• timestamps;
• cookie identifiers;
• approximate location information derived from technical data;
• website analytics; and
• other technical information.

Security Information

Where Aston uses cameras or other security systems at its premises, we may collect video or images for security, fraud prevention, loss prevention, incident investigation and protection of persons and property.

Individuals are responsible for ensuring that information supplied to Aston Auto Innovation is accurate, complete and not misleading.

Aston Auto Innovation is generally entitled to rely on information voluntarily supplied by customers, applicants, vehicle owners, prospective customers and their authorized representatives unless Aston knows or reasonably should know that the information is inaccurate.

Aston is not responsible for losses, delays, financing decisions, registration issues, transaction failures or other consequences resulting from inaccurate, incomplete, fraudulent, outdated or misleading information supplied by an individual or by a third party acting on that individual's behalf, except to the extent that liability cannot lawfully be excluded.

If you provide personal information relating to another individual, you represent that you are authorized to provide that information where authorization is required.

Customers must promptly advise Aston Auto Innovation of material changes to information relevant to an ongoing transaction.

Aston Auto Innovation may collect, use and process personal information for purposes reasonably connected with its business, including:

• responding to vehicle inquiries;
• verifying identity;
• scheduling appointments;
• administering test drives;
• purchasing vehicles;
• selling vehicles;
• processing trade-ins;
• establishing vehicle ownership;
• determining vehicle history;
• obtaining vehicle-history reports;
• identifying liens or other registered interests;
• completing registration and licensing;
• preparing contracts and bills of sale;
• processing payments and deposits;
• facilitating financing;
• submitting financing applications;
• communicating with lenders;
• preventing fraud;
• verifying information;
• conducting compliance checks;
• carrying out security investigations;
• administering warranties;
• managing customer complaints;
• handling refunds and chargebacks;
• collecting amounts owing;
• responding to legal claims;
• defending Aston's legal rights;
• maintaining transaction records;
• complying with accounting and taxation requirements;
• meeting OMVIC or other regulatory requirements;
• complying with court orders, subpoenas and lawful demands;
• improving business operations;
• maintaining information systems;
• website analytics;
• advertising and marketing where permitted;
• preventing cybersecurity threats;
• managing business risks;
• evaluating potential or actual corporate transactions; and
• other purposes reasonably connected to a transaction and permitted by law.

Personal information may also be retained and used where reasonably necessary to establish, exercise, preserve or defend Aston Auto Innovation's contractual or legal rights.

When you ask Aston Auto Innovation to assist in obtaining vehicle financing, Aston may act as an intermediary between you and prospective lenders.

Aston Auto Innovation is not itself necessarily the lender and does not control an independent lender's:

• credit criteria;
• underwriting requirements;
• interest-rate determination;
• approval or decline decision;
• requested documentation;
• funding conditions;
• loan administration;
• privacy practices; or
• subsequent servicing of a loan.

Subject to applicable authorization and law, Aston may submit information to one or more prospective lenders or financing providers in seeking financing for an applicant.

Where a credit bureau inquiry requires specific consent or authorization, that authorization may be contained in a separate financing or credit application.

No Guarantee of Financing

Submission of a financing application does not constitute:

• a guarantee of approval;
• a guarantee of a particular interest rate;
• a guarantee of particular financing terms;
• a commitment by Aston to provide financing;
• a commitment by any lender to provide financing; or
• a representation that financing will remain available for any particular period.

Financing approvals may be conditional, withdrawn, changed or subject to additional documentation according to the applicable lender's requirements and applicable law.

To the maximum extent permitted by law, Aston Auto Innovation is not responsible for an independent lender's credit decision, underwriting criteria, interest rate, approval conditions or refusal to provide financing.

Aston Auto Innovation reserves the right, where permitted by law, to verify information submitted in connection with a transaction.

This may include verification with:

• lenders;
• employers;
• financial institutions;
• credit reporting organizations;
• government agencies;
• vehicle registries;
• lien registries;
• vehicle-history providers;
• identity-verification providers;
• payment providers;
• insurers; and
• fraud-prevention services.

Where Aston reasonably suspects fraud, identity theft, falsified documentation, payment fraud, vehicle theft or other unlawful activity, information may be retained, investigated and disclosed to appropriate parties where permitted or required by law.

Aston Auto Innovation may decline, suspend or terminate a proposed transaction where reasonably necessary to address fraud, security, compliance or identity-verification concerns, subject to applicable law and existing contractual obligations.

Aston Auto Innovation may disclose personal information where reasonably necessary for the purposes identified in this Policy, with appropriate consent where required, or otherwise as permitted or required by law.

Recipients may include:

• financial institutions;
• banks;
• lenders;
• credit reporting agencies;
• payment processors;
• vehicle-history providers;
• warranty providers;
• insurance providers;
• transportation providers;
• vehicle auction providers;
• vehicle registration services;
• government agencies;
• ServiceOntario;
• the Ontario Ministry of Transportation;
• OMVIC;
• law-enforcement authorities;
• courts and tribunals;
• accountants;
• lawyers;
• insurers;
• auditors;
• cybersecurity providers;
• software providers;
• cloud providers;
• CRM providers;
• website providers;
• advertising providers;
• analytics providers;
• communications providers;
• debt-collection providers;
• professional advisers; and
• other parties reasonably involved in the transaction or Aston's operations.

Aston Auto Innovation does not sell customer personal information as a standalone commodity to unrelated third parties for their independent marketing purposes.

Aston Auto Innovation depends on independent third parties to provide services necessary to operate a modern automotive dealership.

These may include lenders, financial institutions, payment processors, cloud providers, website platforms, CRM providers, communications providers, credit reporting agencies, vehicle-history databases and government systems.

Aston does not control the independent operations, security systems, availability, decisions or privacy practices of third parties acting in their own capacity.

Although Aston takes reasonable measures regarding providers handling information on its behalf where required by law, Aston cannot guarantee that an independent third party will never experience:

• a cybersecurity incident;
• system outage;
• service interruption;
• unauthorized access;
• data loss;
• processing error; or
• other operational failure.

To the maximum extent permitted by applicable law, Aston will not be responsible for the independent acts, omissions, decisions, representations or privacy practices of third parties that are not acting under Aston's direction or control.

Nothing in this section relieves Aston Auto Innovation of a responsibility that applicable law expressly places upon Aston.

Aston Auto Innovation may obtain vehicle information from sources such as:

• CARFAX or similar providers;
• government databases;
• lien registries;
• auctions;
• prior owners;
• repair facilities;
• inspectors;
• manufacturers;
• insurers; and
• other automotive databases or sources.

Such information may originate from independent third parties.

Aston cannot guarantee that third-party databases are complete, current or error-free.

Third-party reports should not be treated as a guarantee that every accident, repair, lien, ownership event, mileage discrepancy or other event concerning a vehicle has been recorded.

Aston Auto Innovation remains responsible for disclosures specifically required of it by applicable motor vehicle dealer legislation and regulations.

Aston may advertise or communicate through services operated by third parties, including vehicle marketplaces and social-media platforms.

Those services operate independently from Aston Auto Innovation.

Information you provide directly to Facebook, Instagram, TikTok, WhatsApp, Google, marketplace providers or another third-party service may be handled according to that provider's own terms and privacy practices.

Aston is not responsible for the operation, security, availability or privacy practices of independent websites, platforms or applications that Aston does not control.

A link, advertisement or reference to a third-party service does not constitute a representation or warranty regarding that third party's privacy or security practices.

Customers should avoid transmitting highly sensitive financial or identification information through public social-media channels.

Customers acknowledge that ordinary email, SMS, social media and internet-based communication may involve security risks outside Aston Auto Innovation's reasonable control.

Unless Aston specifically provides a secure method for submitting highly sensitive information, customers should exercise caution when transmitting items such as banking information, credit documents or government identification electronically.

Aston will take reasonable measures appropriate to the sensitivity of information under its control but cannot guarantee the absolute security of information while it is travelling through telecommunications networks, email systems or third-party platforms outside Aston's control.

Aston is not responsible for unauthorized access resulting solely from circumstances outside Aston's reasonable control, including compromise of a customer's:

• email account;
• telephone;
• password;
• telecommunications provider;
• device;
• social-media account; or
• other personal technology,

except where applicable law provides otherwise.

Customers are responsible for taking reasonable measures to protect their own information and communications.

This includes protecting passwords, email accounts, mobile devices and any accounts used to communicate with Aston.

Customers should promptly notify Aston if they reasonably believe:

• a communication purporting to come from Aston is fraudulent;
• payment instructions may have been altered;
• an account used to communicate with Aston has been compromised; or
• personal information sent to Aston may have been intercepted.

Aston may take additional verification steps before acting on unusual payment instructions, account changes or requests involving sensitive information.

Aston Auto Innovation may use banks or independent payment processors to process payments.

Payment information supplied to an independent processor may be subject to that processor's own terms and privacy practices.

Aston is not responsible for payment-system failures or unauthorized transactions caused by an independent processor or financial institution outside Aston's reasonable control, except where liability is imposed on Aston by applicable law.

Customers remain responsible for ensuring payment information provided to Aston is authorized and accurate.

Aston reserves all rights available under law concerning fraudulent, reversed, disputed or dishonoured payments.

Where permitted by applicable law, Aston Auto Innovation may communicate with customers or prospective customers regarding:

• available vehicles;
• financing opportunities;
• dealership promotions;
• special offers;
• warranty products;
• vehicle-buying opportunities; and
• related products or services.

Commercial electronic communications will be sent only where Aston has a lawful basis to do so, including valid express or implied consent where applicable.

Recipients may withdraw applicable marketing consent or unsubscribe using the mechanism provided in a commercial message or by contacting Aston.

Withdrawal of marketing consent does not prevent Aston from sending communications that are reasonably necessary to:

• administer an existing transaction;
• respond to an inquiry;
• provide requested information;
• administer financing;
• communicate regarding payment;
• address a dispute;
• administer a warranty;
• comply with law; or
• protect Aston's legitimate legal interests where otherwise permitted by law.

Aston's website may use cookies and related technologies for purposes such as:

• website functionality;
• security;
• analytics;
• remembering preferences;
• measuring advertising;
• improving website performance; and
• understanding visitor behaviour.

Third parties providing analytics, hosting or advertising services may also use technology in connection with their services.

Users may adjust browser settings to restrict cookies, although doing so may prevent portions of the website from functioning correctly.

Where separate consent for particular tracking technologies is legally required, Aston will seek such consent.

Aston Auto Innovation may maintain records documenting customer communications, negotiations, consents, disclosures, vehicle transactions and financing activities.

Such records may include:

• signed documents;
• electronic signatures;
• emails;
• text messages;
• CRM records;
• transaction notes;
• financing communications;
• payment records;
• website submissions;
• vehicle records; and
• other business records.

These records may be relied upon where reasonably necessary to:

• establish what occurred during a transaction;
• respond to a customer complaint;
• address a chargeback;
• enforce a contract;
• collect an amount owing;
• defend a legal claim;
• respond to an OMVIC or government inquiry;
• demonstrate regulatory compliance; or
• protect Aston Auto Innovation's legal interests.

A customer's subsequent withdrawal of consent does not require Aston to erase records that Aston is legally required or otherwise legally entitled to retain.

Aston Auto Innovation may use surveillance cameras at dealership premises for purposes including:

• safety;
• theft prevention;
• fraud prevention;
• protection of vehicles;
• protection of employees and customers;
• investigation of incidents; and
• protection of property.

Surveillance footage may be reviewed internally or disclosed to insurers, law enforcement, legal advisers or other authorized parties where reasonably necessary and permitted by law.

Footage will be retained according to Aston's applicable retention practices unless a longer period is reasonably required for an investigation, dispute, insurance matter or legal proceeding.

Aston Auto Innovation uses administrative, physical and technical safeguards that are reasonable and appropriate in the circumstances having regard to the sensitivity of information.

Safeguards may include:

• restricted access;
• passwords;
• role-based access controls;
• secure storage;
• cybersecurity software;
• authentication controls;
• employee confidentiality obligations;
• staff training;
• physical security;
• vendor controls;
• backup systems;
• encryption where appropriate; and
• secure disposal procedures.

However, no physical or electronic information system is completely immune from failure, human error, unauthorized access, malicious activity or cyberattack.

Accordingly, Aston does not represent or warrant that unauthorized access, loss, misuse or disclosure can never occur.

The existence of a security incident does not, by itself, establish that Aston Auto Innovation failed to meet a legal duty or applicable standard of care.

Nothing in this section limits Aston's statutory obligation to maintain safeguards required by applicable law.

If Aston becomes aware of a suspected privacy or cybersecurity incident affecting personal information under its control, Aston may investigate the matter and take measures Aston reasonably considers appropriate.

Where required by PIPEDA or another applicable law, Aston will make required reports and notifications.

The timing, extent and content of any notice will be determined according to the circumstances and applicable legal requirements.

Aston reserves the right to take actions reasonably required to investigate, contain and remediate an incident before making statements regarding responsibility or cause.

No notification or remedial action taken by Aston shall, by itself, constitute an admission of negligence, fault or legal liability.

Information may be stored or processed:

• in Ontario;
• elsewhere in Canada; or
• outside Canada,

depending on the service providers and systems Aston uses.

Information processed outside Canada may be subject to the laws of the jurisdiction in which it is processed and may be accessible to governmental, regulatory or law-enforcement authorities according to applicable law.

Aston may select and change technology or service providers in the ordinary course of business.

Where required by privacy law, Aston will maintain measures appropriate to protect information transferred to service providers for processing.

Aston Auto Innovation may retain personal information for as long as reasonably necessary for:

• the transaction for which it was collected;
• vehicle-dealer recordkeeping requirements;
• financing administration;
• warranty administration;
• accounting;
• taxation;
• fraud prevention;
• security;
• dispute resolution;
• chargebacks;
• debt collection;
• litigation;
• regulatory inquiries;
• enforcement of contracts; and
• other legitimate purposes permitted by law.

The expiry or termination of a customer relationship does not necessarily require immediate destruction of transaction records.

Information may be retained beyond ordinary retention periods where reasonably necessary because of:

• anticipated or existing litigation;
• regulatory investigation;
• law-enforcement request;
• preservation obligation;
• outstanding debt;
• fraud investigation;
• warranty matter;
• audit; or
• other legal requirement.

When Aston determines that information is no longer reasonably required and no legal basis exists for further retention, Aston may securely destroy or anonymize the information.

Vehicles may contain personal information belonging to previous owners or users, including:

• saved telephone numbers;
• text messages;
• call histories;
• home addresses;
• navigation history;
• garage-door codes;
• app information;
• Bluetooth pairings;
• connected accounts; and
• other stored information.

Individuals selling or trading vehicles to Aston Auto Innovation are responsible for removing personal belongings and are strongly encouraged to erase personal data and disconnect personal accounts before surrendering the vehicle.

Aston may perform factory resets or other reasonable data-removal procedures as part of vehicle preparation.

To the fullest extent permitted by law, Aston is not responsible for personal information voluntarily left in a surrendered vehicle where Aston did not intentionally collect that information and Aston has acted reasonably in preparing the vehicle for resale.

Subject to applicable law, individuals may request access to personal information Aston maintains about them and may request correction of inaccurate information.

Aston may require sufficient information to verify the identity and authority of the requester.

Aston may deny or limit access where permitted or required by law, including where information:

• relates to another person;
• is protected by legal privilege;
• contains confidential commercial information;
• relates to an investigation;
• cannot be disclosed without revealing another individual's personal information; or
• is otherwise legally protected from disclosure.

Aston will respond according to applicable legal requirements.

Where processing is based on consent, an individual may withdraw consent subject to:

• reasonable notice;
• applicable law;
• contractual restrictions;
• transactions already undertaken;
• regulatory retention requirements; and
• Aston's legal rights.

Withdrawal does not retroactively invalidate lawful collection, use or disclosure that occurred before the withdrawal became effective.

Where information is necessary to provide a requested product or service, withdrawal may make it impossible for Aston to continue providing that product or service.

If Aston Auto Innovation undergoes or considers:

• financing;
• restructuring;
• merger;
• acquisition;
• sale;
• transfer of assets;
• reorganization;
• insolvency proceeding; or
• similar business transaction,

personal information may be reviewed or transferred as permitted by applicable law and subject to appropriate confidentiality or privacy protections where required.

Aston Auto Innovation may collect, retain, use and disclose information where reasonably necessary and legally permitted to:

• investigate suspected misconduct;
• investigate fraud;
• respond to complaints;
• enforce agreements;
• recover amounts owing;
• establish legal claims;
• defend legal claims;
• respond to insurers;
• respond to regulators;
• cooperate with law enforcement;
• obtain legal advice; or
• protect the rights, safety, property and legitimate interests of Aston Auto Innovation, its employees, customers or others.

Information relevant to an anticipated or existing legal dispute may be preserved notwithstanding an otherwise applicable destruction schedule.

To the maximum extent permitted by applicable law, Aston Auto Innovation is not liable for losses arising solely from:

• acts or omissions of independent lenders;
• credit reporting agencies;
• banks;
• payment processors;
• government systems;
• vehicle-history providers;
• telecommunications providers;
• third-party websites;
• marketplace platforms;
• social-media companies;
• independent service providers;
• unauthorized actions of customers;
• compromised customer accounts or devices; or
• events outside Aston's reasonable control.

This provision does not exclude any liability that Aston Auto Innovation is prohibited by law from excluding.

Aston Auto Innovation will use safeguards appropriate to its legal obligations and the circumstances.

However, Aston does not guarantee or warrant that its website, telecommunications networks, databases, software systems, cloud providers or other information systems will:

• operate without interruption;
• be completely error-free;
• never experience a security vulnerability; or
• be completely immune from unlawful third-party activity.

Nothing in this Privacy Policy constitutes a warranty of absolute cybersecurity.

Information appearing on Aston's website is provided for general informational and commercial purposes.

Website content may change without notice.

Vehicle availability, pricing, financing estimates, payment examples, photographs, specifications and third-party information displayed online may be subject to verification and the terms of a final written transaction.

Nothing contained in this Privacy Policy alters mandatory disclosure obligations imposed on Aston Auto Innovation under applicable motor vehicle dealer or consumer-protection legislation.

This Privacy Policy describes Aston Auto Innovation's privacy practices.

It does not create contractual, fiduciary or other duties beyond those imposed by applicable law or separately agreed to by Aston in writing.

Nothing in this Privacy Policy creates a guarantee, warranty or representation regarding:

• financing approval;
• availability of any vehicle;
• vehicle condition;
• future vehicle value;
• third-party services; or
• uninterrupted operation of Aston's website or systems.

To the fullest extent permitted by applicable law, Aston Auto Innovation shall not be liable for indirect, incidental, special or consequential losses arising solely from circumstances outside Aston's reasonable control in connection with the handling or transmission of information.

Nothing in this Privacy Policy limits or excludes liability where such limitation or exclusion is prohibited by applicable law.

No provision of this Privacy Policy shall be interpreted as waiving a consumer right that cannot legally be waived.

If any provision of this Privacy Policy is determined by a court or competent authority to be invalid, illegal or unenforceable, that provision will be interpreted or limited to the minimum extent necessary to make it enforceable where legally possible.

The remaining provisions will continue in effect to the extent permitted by law.

Subject to any mandatory legal rights that apply to an individual, this Privacy Policy and Aston Auto Innovation's privacy practices will be governed by applicable Canadian federal law and the laws of the Province of Ontario.

Nothing in this provision limits the jurisdiction or authority of a privacy commissioner, regulator or other body where jurisdiction is established by law.

Aston Auto Innovation may revise this Privacy Policy from time to time to reflect:

• changes in law;
• regulatory requirements;
• business operations;
• technology;
• service providers;
• security practices; or
• services offered.

The current version will be made available through Aston's website or other appropriate means.

Where applicable law requires additional notice or consent for a material change, Aston will provide such notice or seek such consent.

Continued retention of previously collected information following a policy update does not authorize Aston to use that information for a materially different purpose where additional consent is legally required.

Questions or complaints concerning Aston Auto Innovation's handling of personal information should first be directed to Aston's Privacy Officer.

Aston may investigate a complaint, request additional information and take corrective measures it considers appropriate based on the circumstances and its legal obligations.

Nothing in this section limits an individual's statutory right to contact an applicable regulator.

Except where prohibited by applicable law, Aston Auto Innovation reserves all rights, remedies, defences and protections available to it under:

• contract;
• statute;
• regulation;
• common law;
• equity; and
• any other applicable legal principle.

Nothing contained in this Privacy Policy shall be interpreted as an admission of liability, assumption of liability, waiver of a defence or waiver of any legal right available to Aston Auto Innovation.

Aston Auto Innovation takes reasonable measures to protect personal information while operating an efficient, secure and legally compliant automotive dealership.

Customers are expected to provide accurate information, protect their own accounts and communication channels, and use reasonable care when transmitting sensitive information.

Aston Auto Innovation will fulfil the responsibilities imposed upon it by applicable law but does not assume responsibility for matters outside its control or for obligations that have not been imposed upon or expressly accepted by Aston Auto Innovation.