Last Revised: October 11, 2023
This Policy describes how we may collect, use, disclose, retain, dispose and otherwise process (collectively, “process”), and how you may correct, update and access, your personal information that you provide or that we collect through our website www.caoec.ca and the related tools, databases, websites, software, products and services, including our driver training database (together, the “Services”).
PLEASE READ THIS POLICY CAREFULLY. By using our Services, or otherwise by choosing to provide your personal information to us, you acknowledge and consent to CAOEC processing your personal information in Canada in accordance with this Policy and as may be further identified when the personal information is collected. If you do not consent to that processing of your personal information, please do not access or continue to use any of our Services or otherwise provide any personal information to us.
KEY ELEMENTS OF THIS POLICY
|For information about:||See:|
|the information that we collect||section 1|
|the purposes for which we collect, use and disclose information||section 3|
|how we disclose and share information||section 4|
|how we may share information with service providers||section 5|
|our approach to consent||section 6|
|the limits on our collection, use, disclosure and retention of personal information||section 7|
|how we keep personal information secure||section 8|
|how you can access and correct your personal information||section 9|
|how you can correct your personal information||section 10|
|how to make inquiries or complaints regarding our privacy practices||section 12|
When you use our Services, we may collect the following personal information from you:
- Contact information, such as name, email address, mailing address, and phone number;
- Employment information, such as employment status, employer name, position and/or title, job description and training records;
- Demographic information, such as date of birth;
- Qualifications, such as driver’s license number and expiration date, and driver abstract and demerits;
- Payment information such as billing address and credit card details; and
- Any other information you voluntarily provide through our Services or by phone or email.
- You make purchasers via our website;
- You fill out free-form fields on our Services;
- You connect with us through social media;
- You communicate with us by phone or email; and
- You otherwise use our Services.
Collection from Third Parties
We do not knowingly collect your personal information from a third party unless you consent or we are otherwise exempted, required or permitted by applicable laws to do so. For example, we may collect your personal information from the following third parties:
- Your employer (for example, if you are participating in our driver training database);
- Your authorized representative(s);
- Organization(s) that you previously provided consent to in respect of their collection of your personal information; or
- Public sources in which your personal information is publicly available.
Links to Other Sites
Our Services may contain links to third-party software, websites, applications or Internet resources (“Third-Party Services”) that are provided solely for your convenience and information. When you click on one of those links you are contacting those Third-Party Services. We do not endorse, and have no responsibility or liability for, or control over, those Third-Party Services or their processing of your personal information. We encourage you to read their privacy policies to learn how they process your personal information.
Cookies are small pieces of information that we may store on the computer or device that you are using that uniquely identifies your browser or device. Cookies typically do not contain data that directly identifies you.
We also collect information about the way you use our Services. For example, the site from which you came and the site to which you are going when you leave our Services, the pages you visit, the links you click on, how frequently you access our Services, whether you open emails or click the links contained in emails, whether you access our Services from multiple devices, last login time, and other actions you take on our Services.
- To operate, maintain and provide the Services;
- To carry out your purchase transactions;
- To verify and authenticate your identity;
- If you participate in our driver training database, to verify your training qualification and driving details;
- To ensure that the Services are optimized for your use and benefit;
- To analyze user experience and improve the Services;
- To maintain accurate records;
- To provide you with requested information and answer your questions;
- To communicate with you to provide you with information about us (including news releases, newsletters and notices regarding upcoming events, new products, etc.);
- To solicit feedback from you about your satisfaction and experience with our services (including through occasional surveys);
- To communicate with you to provide you services;
- To carry out our obligations arising from any contracts entered into between you and us;
- To comply with internal policies and procedures and other legal, regulatory, accounting, or security requirements; and
- To provide personal information to third-party suppliers of products and services (as discussed in more detail below);
- To manage or transfer our assets or liabilities, for example, in the case of an acquisition or merger, the provision of security for a credit facility or the change of a supplier of products or services;
- To protect us, yourself and others from fraud and error and to safeguard our business interests;
- To collect debts owed to us; and
- To distribute to third parties including financial institutions, payment processors, lawyers, financial institutions and government licensing bodies for any of the above purposes.
We may disclose your personal information for the purposes as described in this Policy in the following ways:
- To our employees, contractors and consultants;
- If you participate in our driver training database, to your employer, as authorized by you;
- To our business partners;
- To our service providers, as discussed below;
- To law enforcement, government or regulatory bodies, or other lawful authorities; and
- To third parties, in accordance with applicable law, in connection with a corporate re-organization, a merger or amalgamation with another entity, or a sale of all or a substantial portion of our assets, provided that the disclosed information continues to be used solely for the purposes permitted by this Policy by the entity acquiring the information.
Our service providers may be located outside of Canada, and you acknowledge that personal information may be processed and stored in foreign jurisdictions with different (and perhaps weaker) privacy laws, and that the governments, courts or law enforcement or regulatory agencies in those jurisdictions may be able to obtain disclosure of that personal information through the laws of the foreign jurisdiction.
If you do not consent to the processing of your personal information in accordance with this Policy, please do not access or continue to use any of the Services or otherwise provide any personal information to us.
You may refuse to provide consent or notify us at any time that you wish to withdraw or change your consent to the processing of your personal information without penalty, subject to legal, contractual or other restrictions and reasonable notice, by opting out of the use of your personal information by contacting our Privacy Officer (see Section 10 below). However, if you withdraw or change your consent, we may not be able to provide you with the Services.
Aside from consent, we may also process your personal information under other legal bases, as permitted by applicable laws.
Your personal information will only be used or disclosed for the purposes set out above and as authorized by law.
We will keep personal information used to make a decision affecting you for at least one year after using it to make the decision.
We 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 a legal or business purpose.
If you participate in our driver training database and you cease to be employed by your current employer, then your driver record will be disassociated from that organization but will stay in the database (unconnected to any organization) until either: (a) you take a position with a new organization and they add your record to their roster, at which point your record will be associated with the new organization; or (b) your training qualification expires, at which your driver record will be deleted after a reasonable period.
We will take reasonable measures, through contractual or other reasonable means, to ensure that our suppliers or agents who assist in providing services implement a comparable level of personal information protection.
However, no method of transmission over the Internet, or method of electronic storage, is completely secure. As such, despite our safeguards and protocols, we cannot fully guarantee the security of your personal information and you should always exercise caution when disclosing personal information over the Internet.
Upon your written request, we will provide you your personal information under our control. We will also give you information about the ways in which that information is being used and a description of the individuals and organizations to whom that information has been disclosed. We may charge you a reasonable fee for doing so.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
If you demonstrate the inaccuracy or incompleteness of personal information, we will amend the information as required. If appropriate, we will send the amended information to third parties to whom the information has been disclosed.
If a challenge regarding the accuracy of personal information is not resolved to your satisfaction, we will annotate the personal information under our control with a note that the correction was requested but not made.
We may update this Policy from time to time to ensure ongoing compliance with applicable laws and for any other purpose that we deem reasonably necessary. We therefore recommend that you review it periodically to ensure you are aware of any changes.
If we make any material changes, we will either (a) notify you by email (sent to the email address listed in our records), or (b) provide a notice on the Services before the change becomes effective. Any change to this Policy will apply to existing information, as well as information collected after the date that this Policy is posted or on the date as specified in the notice. Your continued use of the Services following the effective date of any changes to this Policy signifies your acceptance of such changes.
If you have any questions or concerns regarding our compliance with this Policy and our processing of your personal information, you may contact our Privacy Officer at email@example.com.
If you are not satisfied with our Privacy Officer’s response to your question or concern, you may be able to file a complaint under applicable privacy laws. Our Privacy Officer will provide you with the contact information to do so, if requested.