Last updated: May 21th, 2021

At Commut Technologies Inc. (“Commut”, “we” or “us” and terms of similar meaning), we are committed to your privacy.  This means we do not transfer, distribute, disclose, rent or sell any of your Personal Information to third parties except as provided for in this policy (the “Privacy Policy”) or as specifically consented by you.

Commut has developed policies and procedures consistent with the Personal Information Protection and Electronic Documents Act (“PIPEDA”), and other relevant privacy laws. By accepting this Privacy Policy in registration or by visiting and using the Commut platform, our mobile application and/or website (the “Commut Platform”) and/or utilizing the services through the Commut Platform (the “Services”), you accept this Privacy Policy and expressly consent to our collection, use and disclosure of your Personal Information in accordance with this Privacy Policy. This Privacy Policy is incorporated into and subject to our Terms of Service.

This Privacy Policy governs our practices to the collection, use and disclosure of Personal Information that we collect from identifiable individuals, including users of the Services, including drivers and riders, and any individual that provides us with their Personal Information, for example visitors to our website (“Users”).

Personal Information is any information recorded in any form that identifies or can identify an individual and includes any information provided to us by you, including in using the Commut Platform or Services. 

Information You provide to Commut to Use the Services 

Personal Information that We collect form you includes, but is not limited to:

• Registration Information: when you sign up for a Commut account, we collect the information that you provide us, such as your phone number, your home address, your work address, your first name, email, your employer or the community you belong to, and a profile picture. If you decide to signup with a Facebook or Google account we may obtain some of the foregoing information from that platform.  
• Payment Method: when you add a credit card or bank account details. a third party that handles payments for us will receive your credit card information. To keep your financial data secure, we do not store full credit card information on our servers.
• Driver: in addition to basic registration information, drivers must provide us with your driver’s licence information as well as accurate information of the car use for the activity of carpooling (brand, color and registration license number). 
• Your Communications: we will collect any communications and personal information that you provide through our messaging system, email or other correspondence directed to us, or comment and feedback forms.
• Account settings: you can set various preferences and personal details on our customer setting pages.
  
  

Information Commut Collects Automatically When You Use the Commut Platform

• Location Indication : we may collect your geolocation in order to facilitate the ride (e.g letting a rider knowing the driver is on the way) as well as to confirm that carpools are actually taking place for safety purposes.
• Device Information: we collect information from the device and application you use to access the Commut Platform. Device data includes your IP address, web browser type, mobile operating system version, phone carrier and manufacturer, application installations, device identifiers, mobile advertising identifiers, push notification tokens, and, if you register with your Facebook account, your Facebook identifier or if you register with Google connect, your Google identifier.  
• In-app text messages: we have installed an in-app message system that allows you to communicate with other riders and the driver of your next trip. 
• Trip information: we collect information including but not limited to ride information such as the name of drivers and riders, date, time, location, destination, route and payment. 
• Address book contacts: if you permit Commut to access the address book on your device through the permission system used by your mobile platform, We may access and store names and contact information from your address book to facilitate invitations and social interactions that you initiate through the Commut Platform and for other purposes described in this Privacy Policy or at the time of collection (with your consent).

Information Received from Other Parties

• Connection. If you connect to the Commut Platform through integration with a third party service (such as Google or Facebook), we may receive the same type of information we collect from you (described above) directly from those services. 
• Commut Business Partners: if you connect with your company or organization, we may receive additional information from your employers that will help us improve your experience, the matching process, development of the Commut Community and reporting.
• ‍Other Third Parties: we may receive Personal Information about you from other sources. For example, we will receive information from credit card processors regarding whether the credit card details you gave us have been accepted or declined. We may also acquire information about you from other promotional of marketing companies with whom you shared your information and whom you have allowed to provide information to us.

Personal Information does not include information that is aggregated or anonymized in such a manner that it cannot be connected to you or any User. This may include data about trips completed and information about businesses and organizations in the Commut Community aggregated among multiple Users. Such information by itself or together cannot be tracked to a specific individual’s personally identifiable information.

Definitions

To better understand this Privacy Policy, Commut has set out some basic definitions to use when reading and interpreting it.

• Collection: the act of gathering, acquiring, recording, or obtaining Personal Information from any source, including third parties, by any means.
• Consent: voluntary agreement to the collection, use and disclosure of Personal Information for defined purposes. Consent can be either express or implied and can be provided directly by the individual or by an authorized representative. Express consent can be given orally, electronically or in writing, but is always unequivocal and does not require any inference on the part of Commut. Implied consent is consent that can reasonably be inferred from the circumstances or from an individual’s action or inaction.
• Commut Community: means Users who have a registered account with Commut to use the Services.
• Disclosure: making Personal Information available to a third party for that party’s own use.
• Personal Information: information about an identifiable individual that is recorded in any form, but does not include aggregated information or depersonalized that cannot be associated with a User (“Non-Personally Identifiable Information”). 
• Transfer: making Personal Information available to a third party for processing, storage or otherwise, solely to be used on behalf of Commut.
• Use: the treatment, handling and management of Personal Information by and within Commut.
  

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Principles

Commut’s Privacy Policy is organized along the ten privacy principles of PIPEDA.

Principle #1 - Accountability

Commut is responsible for the Personal Information under our possession and control.  We have designated a Privacy Officer to be responsible for our compliance with this Privacy Policy and privacy legislation.

Accountability for Commut's compliance with the provisions of Commut's Privacy Policy rests with the Privacy Office within Commut, which shall designate one or more persons to be accountable for compliance with the Commut policy. Other individuals within Commut may be delegated to act on behalf of designated person(s) or to take responsibility for the day-to-day collection and processing of Personal Information. The Privacy Office has been created to ensure Users have a designated avenue to answer their privacy-related inquiries.

Commut shall make known, upon request, the title of the person or persons designated to oversee Commut's compliance with this policy.

Commut is responsible for Personal Information in its possession or custody, including information that has been transferred to a third party for processing. Commut shall use contractual or other means to provide a comparable level of protection while the information is being processed by a third party.

Commut shall implement policies and practices to give effect to these principles, including:

• Implementing procedures to protect Personal Information;
• Establishing procedures to receive and respond to complaints and inquiries;
• Training staff and communicating to staff information about the organization’s policies and practices; and
• Developing information to explain the organization’s policies and procedures.
  

Principle #2 – Identifying Purposes

Personal Information

Commut collects Personal Information for the following purposes:

• to provide Services to our Users;
• to establish and maintain responsible commercial relations and to communicate with you in order to provide service. This includes, but is not limited to, communications relating to billing, payments, advertising, promotion and account verification;
• to respond to any correspondence you may direct to us;
• to understand, research, and improve our Services, including User feedback;
• to communicate with you regarding customer service issues and/or product or service issues; 
• to direct advertisements to you about our company and our products and services that may be of interest to you;
• to enforce our Terms of Service and other legal agreements;
• to provide you with system or administrative messages;
• to monitor the activity of the Commut Platform to ensure safety of the Commut Community and retain a history of your use of the Commut Information; 
• to meet legal and regulatory requirements; and
• for any other reasonable purposes for which you may have provided your express consent or in which your consent can be reasonably implied.
  

Non-Personally Identifiable Information

In an ongoing effort to better understand and serve the users of our Services and improve our Service and user functionality, we conduct research on our customer and User demographics, and behavior based on Personal Information and other information that we have collected.  This research may be used by  Commut to analyze and improve our services to our customers, including the usage and evolution of the Commut Platform.  This research will be compiled and analyzed on an aggregate basis and this aggregate does not identify any individual and therefore is considered and treated as Non-Personally Identifiable Information under this Privacy Policy. We may share such information to third party business partners.

Principle #3 - Consent

The knowledge and consent of the individual are required for the collection, use, or disclosure of Personal Information, except in certain circumstances as described below.

In certain circumstances, Personal Information can be collected, used, or disclosed without the knowledge and consent of the individual. For example, legal, medical or security reasons may make it impossible or impractical to seek consent. When information is being collected for the detection and prevention of fraud or for law enforcement, seeking the consent of the individual might defeat the purpose of collecting the information. Seeking consent may be impossible or inappropriate where there is an emergency threatening the individual's life, health or security, or where the individual is a minor, seriously ill, or mentally incapacitated. In other instances, information may be publicly available. 

Where appropriate, Commut will generally seek consent for the use or disclosure of the information at the time of collection. In certain circumstances, consent with respect to use or disclosure may be sought after the information has been collected but before use (for example, when Commut wants to use information for a purpose other than those identified above).

In obtaining consent, Commut will use reasonable efforts to ensure that a User is advised of the identified purposes for which Personal Information collected will be used or disclosed.

The form of consent sought by Commut may vary, depending upon the circumstances and type of information disclosed. In determining the appropriate form of consent, Commut shall take into account the sensitivity of the Personal Information and the reasonable expectations of its customers and employees.

Commut will seek consent when the information is likely to be considered sensitive. Implied consent will generally be appropriate where the information is less sensitive.  In certain circumstances, your consent may be implied by your actions.  For example, providing us Personal Information to register for our Services is implied consent to use such information to provide you the associated services.

With respect to Personal Information already collected by Commut prior to the publication of this Privacy Policy, this Privacy Policy will constitute reasonable notice to Commut's current Users of the purposes and uses for which such Personal Information has been collected. Should an individual object to these ongoing uses or disclosures, consent may be withdrawn upon providing notice to Commut in writing.

You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice, however, withdrawing consent may result in our inability to provide you with certain Services. In order to withdraw consent, you must provide notice to  Commut in writing.

Principle #4 – Limiting Collection

Commut will limit the collection of Personal Information to that which is necessary for the purposes identified by Commut. Commut will collect information by fair and lawful means.

Commut collects Personal Information from its Users for the purposes described under Principle #2. Commut may also collect Personal Information from such third parties as employers of Users or other third parties that represent they have the right to disclose the information. 

Principle #5 – Limiting Use, Disclosure and Retention

Unless required by law, or in connection with a business transaction,  Commut shall not use or disclose or transfer Personal Information for any purpose other than those described above without first identifying and documenting the new purpose and obtaining your consent, where such consent may not reasonably be implied.

Information Shared Between Users

Commut may share Personal Information among Users in the following circumstances:

• User Profile – we may share your public profile information to the Commut Community members you match with for rides.  A profile is by default your first name, a picture of yourself and the indication of your employer or community your belong to, your rating (5 stars by default), the number of trips you have completed, and when you became an account holder. You have the option of adding further details about yourself (e.g. talk preference) and these details will be accessible to other users in your profile detail. 
• Trip Detail – when you have been matched for a ride, We share with your driver and co-passengers your pick-up and drop-off location signal on a map  . If you are a driver, we share with the rider you have been matched with the information about the brand of your car, color of your car and your car registration number to help riders recognize your car for the pick-up.  
• Trip in-app messages - when you have been matched for a ride, you have access to a message thread with other Users you have been matched with for the coming trip. Only your profile will be accessible to others Users, there is no disclosure of your phone number or other location information. 
• User Feedback - for safety reasons, at the end of every ride, Users must provide their feedback about the trip. This feedback will work as a rating and will impact your score (average of ratings), displayed to others Users.   
• Referral - if you use a referral code provided by another User, we will inform that Use once you have take advantage of this code to trigger his benefits. 

We don’t share your phone number or other contact information with other Users, unless you have given us the consent to do so, for example if you report a lost or found an item to us. We will seek to connect you with the relevant Users.

Information Shared with Our Service Providers

We may provide your Personal Information for processing and handling to our service providers that help us with our business operations and developing our products and services. For example, we share your payment information with a payment processing company so that they may process your payments to us.  We require our service providers to keep your Personal Information secure. In addition, our service providers may not use or disclose Personal Information for any purpose other than providing the services on our behalf unless we or they have obtained your consent.  Commut takes reasonable contractual or other measures to protect your Personal Information while processed or handled by such service providers.

Third Party Services

The Services may allow you to connect with other websites, products, or services to enhance your experience. Your use of these third party services is entirely optional. We are not responsible for the privacy policies and/or practices of these third party services, and you are responsible for reading and understanding those third party services’ privacy policies.

Commut Business Partners

If you connect with your company or organization, we may share information about your use of the Commut Platform, such as the frequency of usage to report about the activity and encourage the development and support of the initiative within your organization. If your trip is paid fully or partly by your organization, we will have to report about the precise activity for tax and payroll reasons.   

Other

We will disclose Personal Information without your knowledge or consent if we receive an order, subpoena, warrant or other legal requirement issued by a court, tribunal, regulator or other person with jurisdiction to compel disclosure of your personal information. If we receive a written request from a police officer or other law enforcement agency with authority to request access to your Personal Information in the course of an actual or potential investigation into a breach of a law, our policy is to provide the requested information.

Your Personal Information may be used or stored by us or our service providers outside of Canada. We require that our service providers safeguard your personal information. However, if your personal information is used or stored outside of Canada, it will also be subject to the laws of the country in which it is used or stored.

In the event your Personal Information is disclosed to a third party pursuant to a business transaction (including a potential sale or financing), Commut will ensure that it has entered into an agreement under which the collection, use and disclosure of the information is related to those purposes that relate to the transaction.

Subject to the foregoing, only Commut’s and our service provider’s employees with a business need to know, or whose duties reasonably so require, are granted access to Personal Information about our Users. All such employees will be required as a condition of employment to contractually respect the confidentiality of your Personal Information.

Commut will retain Personal Information for only as long as required to fulfill the identified purposes or as required by law. Personal Information that is no longer required to fulfill the identified purposes will be destroyed, erased or made anonymous according to the guidelines and procedures established by Commut.  If you wish to deactivate your account, you have to send us an email communitysupport@commut.ca and we will delete your public profile but keep information about your trips and account to prevent any issues related to trust, safety or fraud. 

Principle #6 - Accuracy

Personal Information will be as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.

The extent to which Personal Information will be accurate, complete and up-to-date will depend upon the use of the information, taking into account the interests of the individual. Information will be sufficiently accurate, complete, and up-to-date to minimize the possibility that inappropriate information may be used to make a decision about that individual.

Commut will update Personal Information about Users as and when necessary to fulfill the identified purposes or upon notification by the individual. 

Principle #7 - Safeguards

Commut will protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. The nature of the safeguards will vary depending on the sensitivity of the information that has been collected, the amount, distribution and format of the information, and the method of storage. 

We take administrative, technical and physical measures to safeguard your Personal Information against unauthorized access, unauthorized disclosure, theft and misuse. This includes limiting access of employees to, and the use of, your Personal Information through the use of passwords and graduated levels of clearance. We do not publish all of our security measures online because this may reduce their effectiveness. We take physical precautions to ensure that the computer servers on which your Personal Information is stored and archived are secure and in a controlled environment with limited access. We educate our employees with respect to their obligations to protect your Personal Information.

Commut makes its employees aware of the importance of maintaining the confidentiality of Personal Information. All of Commut's employees with access to Personal Information will be required as a condition of employment to contractually respect the confidentiality of Personal Information.

Commut will protect Personal Information it discloses to third parties through contractual agreements stipulating the confidentiality of the information and the purposes for which it is to be used.

Although we take precautions against possible breaches of our security systems, no company can fully eliminate the risks of unauthorized access to your Personal Information and no website is completely secure. We cannot guarantee that unauthorized access, hacking, data loss or breaches of our security systems will never occur. 

Principle #8 - Openness

Commut shall make readily available to our Users specific information about its policies and practices relating to the management of Personal Information.

Commut will make information about its policies and practices easy to understand, including:

• The title and address of the person(s) accountable for Commut's compliance with the policy and to whom inquiries or complaints can be forwarded;
• The means of gaining access to Personal Information held by Commut; and 
• A description of the type of Personal Information held by Commut, including a general account of its use.

Commut will make this privacy policy available online at www.commut.ca. On request, a copy of this Privacy Policy shall be provided by mail. 

Principle #9 - Individual Access

Upon request, Commut will provide information to a User regarding the existence, use and disclosure of his or her Personal Information.   Commut will respond to an application for individual access to Personal Information within a reasonable time and at minimal or no cost to the individual. A User may challenge the accuracy and completeness of the information and have it amended as appropriate.

NOTE: In certain circumstances, Commut may not be able to provide access to all the Personal Information it holds about a User.  Exceptions may include information that is prohibitively costly to provide, information that contains references to other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons, or information that is subject to solicitor-client or litigation privilege. Commut will provide the reasons for denying access upon request.

Principle #10 - Challenging Compliance

An individual may address a challenge concerning compliance with this Privacy Policy to Commut's Privacy Officer.

Commut will maintain procedures for addressing and responding to all inquiries or complaints from Users about  Commut's handling of Personal Information. Commut shall investigate all complaints.  A User shall direct all inquiries or complaints involving Commut's handling of Personal Information or compliance with this policy or with PIPEDA to Commut's Privacy Officer. 

The Privacy Officer will respond to all such inquiries or complaints within 14 business days of receipt.  The Privacy Officer will make reasonable efforts to resolve all such complaints within 30 days of receipt of the initial complaint. If Commut finds a complaint to be justified, it will take appropriate measures, including, if necessary, amending its policies and procedures.

For more information, please contact our Privacy Office as follows:

E-mail: contact@commut.ca

Mail: Commut Technologies Inc. 365 Church Street, Unit 3006 Toronto, ON M5B 1Z9

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‍Using the Commut Platform & Cookies

In order to improve the Commut Platform, we may use small files commonly known as “cookies”. A cookie is a small amount of data, which often includes a unique identifier that is sent to your computer or mobile phone (your “device”) from the Commut Platform and is stored on your device’s browser or hard drive.  Cookies are used in analyzing trends, administering the site, tracking users’ movements around the site and to gather demographic information about our user base as a whole. We may generate reports based on the use of these technologies an aggregated basis

The cookies we use on the Commut Platform won't collect personally identifiable information about you and we won't disclose information stored in cookies that we place on your device to third parties.  We use cookies to remember users’ settings, store login addresses, authenticate users, run website experiments, and store analytics data, such as browser, device type and operating system. 

Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our site, but your ability to use some features or areas of our site may be limited.

You can find more information about how to do manage cookies for all the commonly used internet browsers by visiting www.allaboutcookies.org. This website will also explain how you can delete cookies which are already stored on your device.

Cookies from third parties  

 We use Google Analytics, a web analytics service provided by Google Inc. ("Google") on the Commut Platform. Google Analytics uses "cookies", which are text files placed on your computer, to help the Commut Platforms analyse how users use the Commut Platform. The information generated by the cookie about your use of the Commut Platforms (including your IP address) will be transmitted to and stored by Google on servers in the United States.  Google will use this information for the purpose of evaluating your use of the Commut Platform, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage.  Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google.  You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of the Commut Platforms.  By using the Commut Platform, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

We may use additional third party and such parties will have their own privacy policies describing how they use information that they collect.

Communication

By using Commut Platform, you agree to receive communications from us via email, text message, calls, and push notifications.  You may unsubscribe from receiving such communications by using the unsubscribe mechanism provided in the communication or by contacting Commut at communitysupport@commut.ca.

For push notifications, you may also manage matching and booking notifications directly in the mobile application. You can also opt-out of receiving push notifications through your device settings. Please note that opting out of receiving push notifications may impact your use of the Commut Platform (such as receiving a notification to inform you about booking, automatic matching and ride informations)

Children and Minors

Our Commut Platform and the Services offered on our Commut Platform are not directed to children under the age of 18 years.  We will not knowingly collect Personal Information about a child under the age of 18. 

General

Commut reserves the right to modify and amend this Privacy Policy from time to time in its sole discretion without prior notice. Any such amendment(s) will be posted on our website and will be effective as of the date of posting.