Last updated: May 12th, 2020
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:
Information Commut Collects Automatically When You Use the Commut Platform
Information Received from Other Parties
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.
Principle #1 - Accountability
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:
Principle #2 – Identifying Purposes
Commut collects Personal Information for the following purposes:
Non-Personally Identifiable Information
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.
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:
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.
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 email@example.com 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:
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
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:
Mail: Commut Technologies Inc. 130 Rusholme Road, #604 Toronto, ON M6H 2Y7
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
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 may use additional third party and such parties will have their own privacy policies describing how they use information that they collect.
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 firstname.lastname@example.org.
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.