This privacy policy (the “Privacy Policy”) describes how Canada Specific Ltd. (“CSL”) collects, uses and discloses information and data relating to your access and use of the CSL Platform, and what rights you have with respect to such information and data. The Privacy Policy forms part of the CSL Terms of Service (the “Terms of Service”) and any capitalized terms used but not defined in the Privacy Policy have the meaning ascribed in the Terms of Service.

The Privacy Policy does not apply to Third Party Services (defined below).

IF YOU DO NOT AGREE WITH THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY, DO NOT ACCESS OR USE THE CSL PLATFORM. BY ACCESSING AND USING THE CSL PLATFORM, YOU AGREE TO THIS PRIVACY POLICY.

CSL reserves the right to update and change the Privacy Policy from time to time by posting updates and changes to the Site. If CSL makes material changes to the Privacy Policy, CSL will send you notice of such changes by posting the revised policy on the Site, and where appropriate, by other means. By continuing to use the CSL Platform after such changes are posted, you agree to such changes.

1. INFORMATION COLLECTED
User Information. CSL collects and receives information and data relating to you during your access and use of the CSL Platform (the “User Information”). User Information includes without limitation identifying information (such as name, address, telephone number, email address, billing information, and banking information), asset information and content (such as photos, images, videos, graphics, written content, audio files or code).
 

Promotional Information. Certain offerings of the CSL Platform, such as newsletters, surveys, contests, and the like are optional and so you are not required to enter them or to give us your data in connection with them. Where you do consent to take advantage of CSL Platform offerings, we will use your data to (as applicable) send you newsletters and other communications that are tailored based on information we have about you, or to operate and manage the survey, contest or similar offering in connection with our legitimate interest in promoting our business and the CSL Platform. To opt-out of receiving marketing communications from us, please see the Choice/Opt-Out section below. CSL follows the Canadian Anti-Spam Legislation (CASL) this means that we need your permission to keep you up to date regarding our products.
 

Other Information. CSL generates and collects information and data that is based on and derived from your use of the CSL Platform (the “Other Information”). Other Information includes, without limitation, the following:

a) Services Metadata. When you interact with the CSL Platform, metadata is generated that provides additional context about the way you engage. For example, CSL logs the
type of communications and services engaged by Users to better understand which features and tools are most used or in need of improvement.
b) Log Data. As with most websites and technology services delivered over the Internet, CSL servers automatically collect and record information when CSL is accessed. This log data may include the Internet Protocol (IP) address, the address of the web page visited before using the CSL Platform, browser type and settings, the date and time the CSL Platform was used, information about browser configuration and plugins, language preferences and cookie data. This Other Information is used to optimize the delivery of the CSL Platform.
c) Device Information. CSL collects information about devices used to access the CSL Platform, including the type of device, what operating system is used, device settings, application IDs, unique device identifiers and crash data. Whether CSL collects some or all of this Other Information often depends on the type of device used and its settings. This Other Information is used to optimize the delivery of the CSL Platform.
d) Location Information. CSL collects information from Users to determine their approximate location, such as their service address, IP address or any other location information from devices in accordance with the consent process provided by the device and, with your consent, precise location data (such as latitude/longitude data). When you visit the CSL Platform via a native mobile application, we use, with your consent when required under applicable law, GPS technology (or other similar technology) to determine your current location in order to determine the city you are located in and display a relevant location map.
e) Cookie Information. CSL uses cookies and similar technologies through the CSL Platform to help collect Other Information. The CSL Platform may also include cookies and similar tracking technologies of third parties, which may collect Other Information about Users via the CSL Platform and across other websites and online services. If you do not wish to accept cookies, you have the option of blocking or disabling cookies. Your computer provides you with the ability to clear all cookies that have been stored onto your hard drive, should you wish to do so. However, please be aware that you may be unable to access certain parts of the CSL Platform if you block or disable CSL cookies.
f) Third Party Services. CSL may receive data about organizations, industries, website visitors, marketing campaigns and other matters related to the CSL Platform from parent corporation(s), affiliates and subsidiaries, CSL partners or others service providers that CSL uses to make the Other Information more useful. This data may be combined with Other Information CSL collects and might include aggregate level data.
g) Additional Information Provided to CSL. CSL receives Other Information when submitted to the CSL Platform or if you participate in a focus group, contest, activity or event, apply for a job, request support, or otherwise communicate with CSL.

h) Content Information. You also may choose to send CSL Personal Information in an email or chat message containing inquiries about the CSL Platform and we use this Information in order to help us respond to your inquiry. We also collect content within any messages you exchange with other Users through the Service (such as through our chat functionality), and we will never use or share such information for marketing purposes.
Generally, you are not under a statutory or contractual obligation to provide any information or data to CSL. However, certain information and data is collected automatically when accessing and using the CSL Platform, and blocking such collections may result in CSL’s inability to provide you with access and use to any part or whole of the CSL Platform. If you do not consent to CSL’s collection of User Information and Other Information, do not access or use the CSL Platform.

2. INFORMATION USE
Service Data. User Information and Other Information (collectively, “Service Data”) will be used by CSL in furtherance of CSL’s legitimate interests in operating the CSL Platform. More specifically, CSL uses Service Data:

a) To provide, update, maintain and protect the CSL Platform. This includes use of Service Data to support delivery of the CSL Platform under the Terms of Service, prevent or address service errors, security or technical issues, analyze and monitor usage, trends and other activities;
b) As required by applicable law, legal process or regulation;
c) To communicate with you by responding to your requests, comments and questions;
d) To develop and provide additional features for the CSL Platform;
e) To send emails and other communications. CSL may send you service, technical and other administrative emails, messages and other types of communications. CSL may also contact you to inform you about changes in the CSL Platform and important service-related notices, such as security notices. These communications are considered part of the CSL Platform and you may not opt out of them. In addition, CSL sometimes sends emails about new product features, promotional communications or other news about CSL. These are marketing messages and you may opt out of them;
f) To operate and contact you for invoicing, account management and other similar reasons; and
g) To investigate and help prevent security issues and abuse. To provide you with customer support in order to fulfill our contracts with Users; To enforce our Terms of Service and our legitimate interests in ensuring our Agreement is complied with; and As otherwise set forth in the Agreement.

3. INFORMATION STORAGE
CSL primarily stores Service Data on servers located outside of Canada and may be operated within the United States. If you reside or are located outside of the U.S., CSL may send and store your Service Data to the U.S. in order to provide and operate the CSL Platform. By accepting the terms of this Privacy Policy, you acknowledge the transfer to and processing of your personal information on servers located in the U.S. and other countries. You specifically acknowledge that all such information may be disclosed by law to the US authorities under the US Patriot Act.
Users of CSL have a right to access their personal information under various Canadian legislation such as the Personal Information Protection Act (PIPA) and the Personal Information Protection and Electronic Documents Act (PIPEDA). This right is subject to exceptions such as if the information would reveal confidential business information
about CSL or personal information regarding another client. Accordingly, if we refuse a request in whole or in part, we will provide the reasons for the refusal.
Requests for personal information may be made in writing to our privacy officer under the contact us section of this agreement.
General inquiries regarding privacy questions may be directed to:

Office of the Information and Privacy Commissioner of Alberta
Suite 500, 640 – 5th Avenue SW
Calgary, Alberta
T2P 3G4

4. INFORMATION RETENTION        
In general, CSL keeps your Service Data throughout your relationship with CSL. This means CSL will keep your Service Data as long as you maintain an Account and/or access or use the CSL Platform.
Once you terminate your relationship with CSL, CSL will generally continue to store archived copies of your Service Data for legitimate business purposes and to comply with applicable law, except when CSL receives a valid erasure request.
If Service Data is aggregated or de-identified so it is no longer reasonably associated with an identified or identifiable natural person, CSL may indefinitely retain and use it for any business purpose.

5. INFORMATION SHARING
This section describes how CSL may share and disclose Service Data.
5.1 Displaying the Services. Service Data may be shared with other Users in the course of the ordinary use of the CSL Platform.
5.2 Third Party Service Providers and Partners. CSL may engage third party companies or individuals as service providers or business partners to process Service Data and support the CSL business. These third parties may, for example, provide virtual computing and storage services, asset information, information specific to your vehicles specific requirements such as service as well as other services.
5.3 Third Party Services. You may access third party software, applications, products, services or website links through the CSL Platform (the “Third Party Services”). When enabled, CSL may share Service Data with Third Party Services. Third Party Services are not owned or controlled by CSL and third parties that have been granted access to Service Data may have their own policies and practices for its collection and use. Please check the privacy settings and notices in these Third Party Services or contact the provider for any questions. CSL disclaims any liability arising in connection with Third Party Services.
5.4 Corporate Affiliates. CSL may share Service Data with its corporate affiliates, parents and/or subsidiaries.
5.5 During a Change to CSL’s Business. If CSL engages in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of CSL’s assets or stock,
financing, public offering of securities, acquisition of all or a portion of the CSL business, a similar transaction or proceeding, or steps in contemplation of such activities (e.g. due diligence), some or all Service Data may be shared or transferred with such participating parties, subject to standard confidentiality arrangements.
5.6 Aggregated or De-identified Data. CSL may disclose or use aggregated or de-identified Service Data indefinitely and for any purpose. For example, CSL may share aggregated or de-identified Service Data with prospects or partners for business or research purposes, such as telling a prospective CSL customer the average amount of time spent within the CSL Platform.
5.7 To Comply with Laws. If CSL receives a request for information from a governing or regulatory authority, CSL may disclose Service Data if CSL reasonably believes disclosure is in accordance with or required by any applicable law, regulation or legal process. CSL is released of any liability associated with any such disclosures made in good faith.
5.8 To Enforce Rights, Prevent Fraud, And For Safety. CSL may disclose or use Service Data to protect and defend the rights, property or safety of CSL or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or security issues.
5.9 With Consent. CSL may share Service Data with third parties when CSL has your consent to do so, which may be obtained through the CSL Platform.
 

6. INFORMATION CONTROL
CSL understands that you have legal rights over your Service Data, and takes reasonable steps in accordance with applicable laws to allow you to access, correct, amend, delete, port, or limit the use of your Service Data. You can update many types of Service Data, such as payment or contact information, directly within your Account. If you are unable to change your Service Data within your Account, please contact CSL to make the required changes.
7. Your Rights and Choices
You may opt-out of receiving promotional communications from us and our Partners, remove your information from our database, choose to not receive future promotional communications related to the CSL Platform, or cancel your account by logging on to the Site(s) and clicking on the “Account” tab, or by contacting us.
Push Notifications. You have the option to receive updates and relevant offers via push notifications in your app. These notifications can be configured in the settings of your mobile device or, for Clients, within the notification settings in your account.
Promotional Communications. You can opt out of receiving promotional communications from CSL sent via email by clicking on the unsubscribe link in any message. You can opt out of receiving promotional communications from CSL sent via text message at any time by following the instructions provided in those messages to
text the word "STOP". Please note that your opt-out is limited to the phone number used and will not affect subsequent subscriptions. You can opt-out of receiving telephone marketing communications by contacting us. If you opt-out of only certain communications, other subscription communications may continue. Even if you opt-out of receiving promotional communications, CSL may continue to send you non-promotional communications, such as those about your account, Jobs, transactions, servicing, or CSL’s ongoing business relationship with you. If you receive unsolicited email from a CSL domain, please let us know, here.
 

8. FEEDBACK
Any suggestions or comments for improving or modifying the CSL Platform that are included in your communications with CSL (“Feedback”) will be deemed to be non-confidential and non-proprietary to you, and you agree that: (a) CSL is therefore not subject to any confidentiality obligations with respect to the Feedback; (b) the Feedback is not confidential or proprietary information of any third party and you have all of the necessary rights to disclose the Feedback to CSL; (c) CSL may irrevocably freely use, reproduce, publicize and exploit the Feedback; and (d) you are not, nor is any other party, entitled to receive any compensation or reimbursement of any kind from CSL in relation to the Feedback.
 

9. SECURITY
CSL works hard to protect the Service Data from loss, misuse, and unauthorized access or disclosure. These steps take into account the sensitivity of the Service Data and the current state of technology. CSL follows industry standards on information security management to safeguard sensitive information, such as financial information, intellectual property, employee details and any other personal information entrusted to CSL. CSL information security systems apply to people, processes and information technology systems on a risk management basis.

No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, CSL cannot guarantee the absolute security of Service Data, and makes no warranties to you in connection with same. CSL does all things reasonable for an organization of their size and scope with regards to security. To the fullest extent allowed by law, the maximum liability for any breach of any privacy law in Canada including Personal Information Protection Act of Alberta or the Personal Information Protection and Electronic Documents Act is a refund of any services paid to CSL.
 

The Parties agree that any disputes will be resolved by way of arbitration which will be governed as follows:
(a) the party desiring arbitration will notify the other party of such desire and the parties will attempt to agree, within five (5) business days, on a single arbitrator who will be named to resolve the dispute. If the parties are unable to agree, if there are only two parties involved in the dispute, each of those parties shall chose an arbitrator and the
two (2) arbitrators shall jointly chose a third arbitrator within five (5) business days of their appointment.
(b) the arbitration will take place in Edmonton, Canada;
(c) the decision of the arbitrator(s) will be final and binding on the parties to the arbitration and no appeal will be taken from any determination unless the determination contains an error of law, which results in a determination which is patently unreasonable;
(d) each of the parties will co-operate with the arbitrator(s) and, subject to the doctrine of privilege, will provide the arbitrator(s) with all information in its possession or under its control necessary or relevant to the matter being determined. The parties will use their reasonable best efforts to cause any arbitration hearing that may be held hereunder to be completed as soon as practicable;
(e) the arbitrator(s) will be required to make an award as soon as possible, and if at all practicable, within ten (10) business days after the conclusion of the arbitration hearing. The arbitrator(s) may determine all questions of law and jurisdiction including questions as to whether the dispute is arbitrable, and has the right to grant permanent and interim relief or injunctive relief or other forms of equitable relief, and will have the discretion to award costs including reasonable legal fees, interest and costs of the arbitration;
(f) except as modified herein, the provisions of the Arbitration Act (Alberta) as amended from time to time, will govern any arbitration conducted under this Contract; and
(g) judgment upon an award, including any interim award, rendered by the arbitrator(s) may be entered in any Court having jurisdiction thereof.
(h) Except where clearly prevented by the nature of the matter in dispute, the affected parties agree to continue performing their respective obligations under the Agreement applicable while the dispute is being resolved or arbitrated unless and until such obligations are terminated or expire in accordance with the provisions of the Agreement.
(i) Nothing in the dispute resolution process will prevent an affected party from applying for or obtaining any interim, interlocutory or preliminary injunctive or declaratory relief or from bringing any claim for contribution or indemnity in the same court in which a suit against the party is brought by any third person.
(j) The parties hereto covenant that they will not apply nor will they have any right to apply by any means to any court to challenge any decision of the arbitrator on a matter properly before the arbitrator.
 

10. CONTACT
10.1 General Contact. You may contact CSL if you have any questions about the Privacy Policy or CSL’s privacy practices, or if you are seeking to exercise any of your rights relating thereto. You may contact CSL at info@canadaspecificltd.ca.

Data Protection Officer. To communicate with CSL’s Data Protection Officer, please email info@canadaspecificltd.ca.

 

 

 

Last updated: 19 Nov 2022