Last Updated: April 14, 2024

COMMCAR PRIVACY POLICY

At Commcar Inc and its affiliates (collectively, “Commcar”, “we”, “our” or “us”), we value your privacy. This Privacy Policy ("Policy") outlines how we collect, handle, store, and share your Personal Information in connection with our services.

This Policy applies to all our operations in Canada, or in connection with Canada, unless we have provided you with a separate privacy policy for a particular product, service, or activity.

Policy Updates

This Policy is current as of the “last updated” date, which appears at the top of this page. We may make changes to this Policy from time to time, which will become immediately effective when published in a revised Policy posted on our website unless otherwise noted. We may also communicate the changes through our services or by other means. Please review this Policy carefully. By submitting your Personal Information to us, registering for, subscribing to, or using any of the services we offer, using our website, or voluntarily interacting with us, you consent to our collecting, using, and disclosing your Personal Information as set out in this Policy, as revised from time to time.

This Policy should be read in combination with Ziip's Terms of Service, available at https://ziip.app/terms-of-service.

What’s in this Policy?

This Policy covers the following topics:

• Meaning of Personal Information
• Your Consent to Collection, Use, and Disclosure
• Personal Information We Collect
• How We Use Your Personal Information
• How We Disclose Your Personal Information
• Opting Out of Communications
• Retention and Storage of Personal Information
• Information Security
• Accessing and Updating Your Personal Information
• Third Party Websites and Services
• Personal Information from Minors
• How to Contact Us

Meaning of Personal Information

"Personal Information" means information about an identifiable individual as described under Canadian privacy laws, which may include, but is not limited to, your name, e-mail address, payment information, route information, delivery and pickup addresses, and telephone number.

In certain circumstances, Personal Information does not include any business contact information that is solely used to communicate with you in relation to your employment, business, or profession, such as your name, position name or title, work address, work telephone number, or work e-mail address. However, such information may be subject to individuals’ rights to access and rectify personal information depending on applicable Canadian privacy laws.

Personal Information also does not include information that has been de-identified, anonymized or aggregated in such a way that it is, at all times, reasonably foreseeable in the circumstances that it no longer allows identification of an individual.

Your Consent to Collection, Use, and Disclosure

We collect, use, and disclose your Personal Information with your consent or as permitted or required by Canadian privacy laws. How we obtain your consent may be express or implied and will depend on the circumstances, as well as the sensitivity of the information collected. If you choose to provide Personal Information to us after we provided access to this Policy, we assume that you consent to the collection, use, and disclosure of that Personal Information as outlined in this Policy.

If you wish to withdraw your consent to our collection, use, or disclosure of your Personal Information, please contact us using the contact information in the “How to Contact Us” section below. In some cases, withdrawal of your consent may mean that we will no longer be able to provide certain products or services.

Personal Information We Collect:

Products and Services: We may collect Personal Information from you or from your use of our products and services, including Ziip. We collect Personal Information that you submit through your registration, subscription, or use of our products and services, such as your contact information, account and profile information, identification documents you provide to permit use of the services for age-restricted products, and Personal Information you may include through communications or content uploaded or shared by you. We may also collect geolocation information when used in conjunction with our products and services, including addresses you visited, routes taken, and other GPS and satellite location information. We may automatically collect technical and usage data that is identifiable to you when you use our products and services, including your internet protocol address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system, mobile or platform device type and other technological information on the devices you may use to access and use our products and services. We will aggregate and anonymize certain data collected in connection with your use of our products and services, which may be stored and used separately from the data and Personal Information referred to above.

Website: For individuals located in Canada who visit our website located at http://www.ziip.ca or any of our related websites (collectively, “our website”), we may collect information from you or from your activities on the site. Like most websites and other Internet services, we may collect certain technical and device information about your use of our website, which may include your Internet protocol address, information about your device, browser, and operating system, and the date and time of your visit, as well as the region or general location where your device is accessing the internet, and other information about the usage of our website, including a history of the pages you view, articles you read, and other behaviours.

We may utilize "cookies" that are technically necessary and that increase the functionality of using our products and services. In addition to cookies, we may use web beacons, and similar technologies when you use our products and services for our business or analytical purposes, such as assessing traffic on our website and understanding how customers utilize our products and services. A “cookie” is a small text file that contains information and is stored on your computer. One type of cookie saves a file permanently on your computer. Cookies will be used to personalize a web page according to the user’s choices and interests. The other main type of cookie is called a “session cookie”. While you are visiting a web page, session cookies are sent between your computer and the server to access information. Session cookies disappear when you turn off your web browser. If you do not wish to accept cookies, your web browser can be set so that you automatically deny the storage of cookies or are informed every time a website requests to be allowed to store a cookie. Previously stored cookies can also be deleted through the web browser. Please refer to your web browser’s help pages for more information. However, please be aware that some areas or features of our products and services rely on cookies and so may not work if you delete or decline cookies. For more information about cookies generally please visit www.allaboutcookies.org.

If you enter information in the “Contact Us” section, we collect your name, email address, phone number, company you represent and details of your inquiry to enable us to respond to a general/business inquiry made by you on behalf of your company.

Interactions: For individuals located in Canada who otherwise interact with us, whether in person, by phone or e-mail, through social media or otherwise, including individuals who might be interested in acquiring our products or services, who sign-up to receive newsletters or other communications, who attend events hosted by Commcar, or who respond to surveys and questionnaires, we may collect information that you provide to us during these interactions. This information may include your name, e-mail address, demographic information (such as your location, gender and age range), professional information (such as your professional designations and name of your employer), your driving habits, your preferred merchants for deliveries and logistics and other information relevant and related to your use and interaction with our products and services, and any other information you may elect to provide to us during these interactions.

Information Collected from Third-Party Companies: We may receive Personal Information or anonymous data about you from companies that offer their products and/or services for use in conjunction with our products and services or whose products and/or services may be linked with ours. For example, payment processors may provide us with your transaction history related to our products and services, the last four digits of the credit card used to purchase a subscription and certain other information you choose to share with that third-party service provider in order to facilitate the purchase and activation of your subscription. We may add this to the data we have already collected from or about you through other means set out in this section.

How We Use Your Personal Information:

We may use your Personal Information for purposes such as:

• providing you with our products and services and supporting your use of our products and services, including facilitating orders and recommendations;
• permitting our third-party service providers, such as our payment processors and communication service providers and online commerce service providers, to provide services related to our products and services;
• contacting you relating to our products and services, including addressing support issues and investigating delivery matters;
• enabling your participation in promotions and contests we may offer from time to time;
• analyzing the behaviour, needs, and activities of you and our users to help us better serve you and them;
• responding to inquiries and other requests;
• generating de-identified data to conduct research and analysis related to our business, products, and services;
• collecting opinions, comments, feedback and survey and questionnaire responses about our products and services;
• developing marketing, promotional, and advertising materials;
• where we have consent to, providing you with information that we think may interest you, including information about our products and services;
• meeting obligations and responding to legal inquiries and requests; and
• for such other purposes as you may otherwise consent from time to time.

We may use your Personal Information for purposes for which we have obtained your consent, and for such other purposes as may be permitted or required by applicable Canadian privacy laws. We will process, collect, use, and disclose information received through our website only to pursue our legitimate business interests in keeping you updated on our services and products, respond to your queries, establish communication with you and your company, and to enhance user experience by analyzing your use of our website.

We may also engage in interest-based advertising (known as targeted or behavioural advertising) in connection with your use of our products and services or our website. Interest-based advertising means that your preferences and interests are collected through cookies or similar technologies and then used to provide you with marketing materials and suggested Commcar content that is relevant to you, based on those preferences and interests. If you are located in the province of Quebec and we collect Personal Information from you using any technology that includes functions allowing you to be identified, located, or profiled, we may be required by law to obtain your distinct express consent to the activation of such functions.

How We Disclose Your Personal Information:

We rely on third-party services providers to perform a variety of services on our behalf, such as payment processors, data storage, security, and processing service providers, online commerce and customer relationship management service providers, email marketing and communication service providers, and research and analytics providers. If we provide information to service providers, we require that the service providers keep your Personal Information secure, and only handle it for limited purposes. We also require that our service providers comply with applicable privacy laws and only use your Personal Information for the limited purposes for which it was provided. We do not authorize the service providers to disclose your Personal Information to unauthorized parties or to use your Personal Information for their direct marketing purposes unless we have your consent to do so. If we are involved in the sale or transfer of some or all of our business, we may disclose your Personal Information in connection with the transfer or sale but will require the acquiring organization to agree to protect the confidentiality of your Personal Information in a manner that is consistent with this Policy. Additionally, we may use and disclose your information when we believe such use or disclosure is permitted, necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce the terms of the agreements for our products and services; (e) to protect our rights, operations or property; and (f) to allow us to pursue available remedies or limit the damages that we may sustain. If we otherwise intend to disclose your Personal Information to a third party, we will identify that third party and the purpose for the disclosure and obtain your consent.

Opting-out of Marketing Communications

To opt-out of receiving marketing-related emails from us, you may opt-out of receiving emails by clicking the “unsubscribe” link at the bottom of any email you receive from us. You may also opt-out by contacting us directly using the contact information in the “How to Contact Us” section below. We will endeavour to respond to your opt-out request promptly, but we ask that you please allow us a reasonable time to process your request. Please note that if you opt-out from receiving marketing-related emails, we may still need to send you communications about your use of our products or services, or other matters.

Retention and Storage of Personal Information

We will use, disclose or retain Personal Information only as long as necessary for the fulfilment of the purposes for which the Personal Information was collected or as permitted or required by Canadian privacy laws. We store all Personal Information in Canada. However, if you access or use our products and services outside of Canada, you may be subject to different data protection rules than those in Canada. While your Personal Information is outside of Canada, it is subject to the laws of the country in which it is located, and those laws may require disclosure of your Personal Information to authorities in that country. For written information about our policies and practices regarding service providers outside of Canada, contact our Privacy Officer at the email address found under the “How to Contact Us” section of this Policy.

Information Security

We have implemented physical, organization, contractual and technological security measures to with a view to safeguarding your Personal Information against unauthorized access, alteration, or destruction. Despite the measures outlined in this section, no method of information transmission or storage is 100% secure or error-free, so we cannot guarantee absolute security. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any information that you provided to us has been compromised), please contact us immediately using the contact information in the “How to Contact Us” section below.

Accessing and Updating Your Personal Information

We expect you, from time to time, to supply us with updates to your Personal Information when required. We will not routinely update your Personal Information, unless such a process is necessary. You may make a written request to review any Personal Information about you that we have collected, used, or disclosed, and we will provide you with any such Personal Information to the extent required by applicable laws. You may also challenge the accuracy or completeness of your Personal Information in our records. If you successfully demonstrate that your Personal Information in our records is inaccurate or incomplete, we will amend the Personal Information as required. In certain circumstances, we may not be able to provide you access to all of your Personal Information it holds, such as where it is prohibitively costly to provide, where it contains references or Personal Information of other individuals, or for security, proprietary or legal reasons, including where the information is subject to solicitor-client or litigation privilege. We will provide you the reasoning and rationale for any denial, in whole or in part, of any request for access to your Personal Information we may hold. We may require that you provide sufficient identification to fulfil your request to access or correct your Personal Information. Any such identifying information will be used only for this purpose. We will not charge you any fees to access your personal information in our records without first providing you with an estimate of the approximate fees, if any. If you object to how we handle your request, you may have the right to make a complaint to the Privacy Commissioner of Canada or the applicable provincial privacy commissioner.

Third Party Websites and Services

We may provide links to third-party websites and services for your convenience and information. Those websites and services are governed by the privacy statements and policies of the respective third party. This Policy does not extend to any websites, products or services provided by third parties. We do not assume responsibility for the privacy practices of third parties and we encourage you to review all third-party privacy policies prior to using third-party websites, products or services.

Personal Information from Minors:

Our Services are intended for individuals of legal age in their respective jurisdictions, and we do not knowingly collect Personal Information from individuals under the age of legal consent. Parents or legal guardians concerned about the collection of their child's Personal Information may contact us using the contact us in the “How to Contact Us” section below.

How to Contact Us:

For comments, inquiries, questions, complains or concerns regarding this Policy or your Personal Information, please contact us at [email protected] or via mail at:

Commcar Inc.

594118 Blind Line, Mono

Attn: Privacy Officer