[Version #2, 2018]
1. COMMITMENT TO PRIVACY
Greenlines Technology Inc. (“Greenlines”, “we”, “us” or “our”) is committed to maintaining the security and privacy of your personal information. This Policy documents our on-going commitment to you and has been developed in compliance with the British Columbia Personal Information Protection Act, S.B.C. 2003, c. 63 ("PIPA").
2. INTRODUCTION & SCOPE OF POLICY
This Policy addresses personal information about individuals and does not apply to information about corporate or commercial entities who are our suppliers or customers. Commercial information may be subject to protection under other policies and practices and through contractual arrangements, including confidentiality agreements. This Policy does not impose any limits on the collection, use or disclosure of the following information by Greenlines:
(a) your business contact information; or
(b) publicly available information recognized under PIPA.
Greenlines is accountable and responsible for personal information under its control. Greenlines has designated a Privacy Officer who is accountable for Greenlines’ compliance with this Policy.
Greenlines will adopt procedures to protect personal information, receive and respond to complaints and inquiries, train staff regarding privacy policies and procedures and communicate policies and procedures to you.
We may collect and process information from you and your device as follows:
(a) once you have given us your consent to track your location, we keep track of your location and movement, including your latitude, longitude, time and speed of travel;
(b) your preferences, including preferred modes of transportation, saved locations and other personal customization that you may select for planning trips;
(c) your name, email, phone number, address and other information you may provide when creating a profile in our mobile application. You are not required to create a profile in order to use our mobile application; however, setting up a profile allows you to take full advantage of the features and functionality of our mobile application;
(d) the amount of greenhouse gas emission saved by your trip (the “Attributes”). The Attributes are non-personal information as they cannot be used to personally identify you. We will aggregate the Attributes and may trade them to improve our services and help us further our mandate to reduce greenhouse gas emissions and improve air quality; and
(e) non-personal information such as usage details each time you use our website and mobile application, including the searches you make, the routes you interact with, the type of phone or OS you are using, etc. We collect such usage related information using analytical technologies to help manage, monitor and optimize our website and mobile application.
Greenlines collects your personal information for the following purposes:
(a) to enable you to access and use the our websites and mobile application;
(b) to provide and administer transportation related products and services requested and to use and disclose personal information for any purpose related to the provision of the requested products and services;
(c) to determine your potential needs and to determine which Greenlines products and services may meet your potential needs;
(d) to evaluate, maintain and improve Greenlines products and services;
(e) to provide you with information about Greenlines products and services, including providing you with marketing material about Greenlines, unless you opt out of receiving this information, as provided below;
(f) to protect Greenlines, yourself and others from error, fraud and other illegal activity and to safeguard the financial interests of Greenlines;
(g) to authenticate your identity and communicate with you;
(h) to collect debts owed to Greenlines;
(i) to manage or transfer assets or liabilities of Greenlines, for example in the case of an acquisition or merger, the provision of security for a credit facility or the change of a carrier; and
(j) to comply with legal and regulatory requirements.
The purposes listed above are a reasonably necessary part of your relationship with Greenlines.
When your personal information is to be used for a purpose not previously identified, the new purpose will be disclosed to you prior to such use, and your consent will be sought unless the use is authorized or required by PIPA or other law.
We use the following cookies on our website:
(a) Strictly necessary cookies - they are essential to navigate around our website and use its features. Without these cookies, services you have asked for cannot be provided. Please note that these cookies do not gather any information about you that could be used for marketing or remembering where you have been on the internet.
(b) Performance cookies - they collect information about how you use our site (e.g. which pages you visit, and if you experience any errors). These cookies do not collect any information that could identify you and is only used to help us improve how our site works, understand what interests our users and measure how effective our content is.
Our website also uses Google Analytics which allows us to track visitor numbers and related information. You can learn about Google’s practices in connection with information collected by Google Analytics and how to opt-out of it by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. However, this may prevent you from taking full advantage of the Site. For more information about cookies and how to disable them, please visit https://www.aboutcookies.org/.
Greenlines will obtain your consent to collect, use or disclose personal information except where Greenlines is authorised or required by PIPA or other law to do so without consent.
Your consent may be express or implied, or given through your authorized representative.
Consent may be provided orally, in writing, electronically, through inaction (such as when you fail to notify Greenlines that you do not wish your personal information collected/used/disclosed for optional purposes following reasonable notice to you) or otherwise. For example, consent may be expressed orally over the telephone at the time information is being collected; electronically, when submitting an agreement, application or other information; or, in writing when signing an agreement or application form.
You may withdraw your consent at any time, subject to legal or contractual restrictions, provided reasonable written notice of withdrawal of consent is given by you to Greenlines. Upon receipt of your written notice, Greenlines will inform you of the likely consequences of the withdrawal, which may include the inability of Greenlines to provide certain services for which the delivery of that information is a prerequisite.
You hereby consent to Greenlines disclosing your personal information to a third party provider under contract with Greenlines for the purposes of providing transportation products and services requested by you and processing payment for such services. In such circumstances the third party shall hold and use your personal information in compliance with privacy laws and shall not disclose your personal information without the consent of Greenlines pursuant to this Policy.
8. LIMITS ON COLLECTION OF PERSONAL INFORMATION
Greenlines will not collect personal information indiscriminately and will limit its collection of your personal information to what is reasonably necessary to provide a product or service and which is reasonably necessary for the purposes consented to by you. Greenlines may also collect information as authorized by PIPA or other law.
9. LIMITS ON SHARING OF PERSONAL INFORMATION
Greenlines will only use or disclose your personal information for the purposes set out above and as authorized by PIPA and other law.
10. RETENTION OF PERSONAL INFORMATION
Greenlines will destroy, erase or make anonymous documents or other records containing personal information as soon as it is reasonable to assume that the original purpose is no longer being served by retention of the information and retention is no longer necessary for legal or business purposes. Greenlines will take due care when destroying personal information so as to prevent unauthorized access to such information.
Greenlines will make a reasonable effort to ensure that personal information it is using or disclosing is accurate and complete. Greenlines will rely on you to ensure that certain information, such as your street address, e-mail address or telephone number, is current, complete and accurate.
If you notify Greenlines of the inaccuracy or incompleteness of personal information, Greenlines will amend the information as required. If appropriate, Greenlines will send the amended information to third parties to whom the information has been disclosed.
When a challenge regarding the accuracy of personal information is not resolved to your satisfaction, Greenlines will annotate the personal information under its control with a note that a correction was requested but not made.
12. SAFEGUARDING PERSONAL INFORMATION
Greenlines protects the personal information in its custody or control by making reasonable security arrangements to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks. Greenlines personnel who have access to your personal information have been trained and are required to maintain the confidentiality of such information.
You should be aware that confidentiality and security are not assured when information is transmitted through e-mail or wireless communication. Greenlines will not be responsible for any loss or damage suffered as a result of a breach of security or confidentiality when information is transmitted by e-mail or wireless communication.
13. STORAGE OF PERSONAL INFORMATION
We do not knowingly collect, use or disclose personal information from persons under the age of majority. If you are under the age of majority in your home country, please do not use our goods or services including our website and mobile applications. If we are made aware that we have collected any Personal Information from a minor without parental consent, and are asked to erase such information from our database, we will do so without undue delay.
15. DO NOT TRACK SIGNALS
Our website and mobile applications do not track users over time and across third party websites to provide targeted advertising and therefore do not respond to Do Not Track (DNT) signals.
We do not allow third-party behavioral tracking. Third parties do not collect any personal information from our website or mobile application unless you provide it to them directly.
16. ACCESS AND YOUR OTHER RIGHTS
You have the following rights in relation to the personal information we hold about you:
(a) Right of Access. You have a right to access your personal information held by Greenlines. Upon written request and authentication of your identity, Greenlines will provide you with personal information under its control, information about the ways in which that information is being used and a description of the individuals and organizations to whom such information has been disclosed.
Greenlines may charge a reasonable fee for providing personal information in response to a PIPA access request and will provide an estimate of any such fee upon receiving a written access to personal information request. Greenlines may require a deposit for all or part of the fee.
Greenlines will make personal information available within 30 days or provide written notice where additional time is required to fulfill the request.
In some situations, Greenlines may not be able to provide access to certain personal information. Greenlines may also be prevented by law from providing access to certain personal information.
Where an access request is refused in whole or in part, Greenlines will notify you in writing, giving the reason for refusal and outlining further steps which are available to you.
(b) Right to rectification. If there is an error or omission in personal information in our custody or under our control for which a request for correction has been received, we will, subject to legal limitations, correct the information as soon as reasonably possible or annotate it with the correction that was requested but not made. If you are entitled to rectification and if we have shared your personal information with others, we will let them know about the correction where possible. If you ask us, where possible and lawful to do so, we will also tell you who we have shared your personal information with so that you can contact them directly.
(c) Right to Withdraw Consent. Please see section 6 above for more information.
17. EUROPEAN DATA SUBJECTS
If you are a resident of one of the European Economic Area (“EEA”, as established on January 1, 1994 upon entry into force of the EEA Agreement) countries, you are entitled to certain rights under the General Data Protection Regulation (EU) 2016/679 (“GDPR”).
Greenlines is the data controller and the data processer of your personal information.
We will only process your personal information if we have obtained your express consent to do so or if we can rely on one or more of the other lawful grounds under GDPR.
(a) You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable). Such request must be in writing and is to be directed to our Privacy Officer.
(b) You can ask us to restrict the processing of your personal information in certain circumstances, such as where you contest the accuracy of that personal information or you object to us. Such request must be in writing and is to be directed to our Privacy Officer.
(c) You have the right, in certain circumstances, to obtain personal information you have provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.
(d) You can ask us to stop processing your personal information, and we will do so, if we are:
i. relying on our own or someone else's legitimate interests to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or
ii. processing your personal information for direct marketing purposes.
(e) If you have a concern about any aspect of our privacy practices, including the way we have handled your personal information, you can report it to the relevant Supervisory Authority
Automated decision making takes place when our electronic systems process your personal information to make a decision about you without human intervention. You will not be subject to decisions that will have a legal or significant impact on you based solely on automated processing, unless we have a lawful basis for doing so and we have notified you.
18. CHANGES TO POLICY
Greenlines Technology Inc.
#151 W Hastings St,
Vancouver, British Columbia V6B 1H4
"collection" means the act of gathering, acquiring, or obtaining personal information from any source, including third parties, by any means;
"consent" means voluntary agreement to the collection, use and disclosure of personal information for specified purposes;
“cookies” means data files that are placed on your device or computer and often include an anonymous unique identifier;
"disclosure" means making personal information available to a third party;
"personal information" means information about an identifiable individual but does not include his or her business contact information. Personal information does not include (a) information concerning corporate or commercial entities or (b) publicly available information. It also does not include information that cannot be associated with a specific individual;
"third party" means an individual or organization other than Greenlines and you;
"use" means the treatment and handling of personal information by and within Greenlines.