Privacy Policy

ON THE MOVE: WHAT YOU NEED TO KNOW

At First Canada ULC and its subsidiaries, including Autobus Transco (1988) Inc. (“First Canada”, “we”, “us”, “our”), we respect your privacy and take steps to protect it. We always recommend that you read this privacy notice in full. It explains who we are, how and why we collect personal information from you, how and why it will be processed by us and our commitment to protecting your information.

But just in case you’re on the move or do not have time to read it in full we have summarized the key points for you in our 'speed read' section below.

  • This privacy notice has been drafted to explain how First Canada collects, uses, discloses, safeguards, and retains information that we collect about you in relation to our services and mobility solutions. It also explains your rights with respect to that information.
  • We have appointed a Privacy Officer who is responsible for our approach to data protection and protecting your privacy. You can contact our Privacy Officer at: CanadaPrivacy@firstgroup.com.
  • Privacy laws in Canada generally define “personal information” as any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person. When information we collect meets the definition of “personal information” under Canadian laws, we will treat it accordingly. More information about the types of personal information we collect is here.
  • We process (i.e. handle) your personal information in connection with our business operations to provide and advertise our services to you. Additional information about the purposes for which we process your information is here.
  • If we are acting as a service provider to one of our customers (e.g., such as when we provide transportation services on behalf of a city a transit authority), we may be collecting your personal information on that customer’s behalf, and so we may make it available to that customer.
  • In some cases, we may disclose your personal information to our business partners and other third parties to who may use the information both for our business purposes and for theirs. More information about how we disclose information is here.
  • We may transfer your personal information to our service providers we use to support our business, including payment processors and data analysts, to enable the efficient and secure provision of services to you. Our service providers are contractually required keep your information confidential and only use it to provide services to us. In some cases, our affiliated companies act as our service providers. More information is available here.
  • When required by applicable law or contract, we keep your personal information in Canada. If not prohibited by law or contract, we may transfer your personal information to our offices and service providers and outside of Canada. More information about when we may make such transfers is here.
  • Generally, we obtain consent to process your personal information. Your consent may be express or implied; which consent we will rely on will depend on the circumstances and the sensitivity of the personal information being processed. When we act as a service provider, our customers may be responsible for obtaining any required consent from you.
  • You have choices about how we use your information. For more information about how to exercise your choices, click here.
  • We take the security of your personal information seriously. We use physical, organizational, administrative, contractual and technological security measures designed to protect your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.
  • Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We may hold anonymized information that cannot identify you indefinitely.
  • Our websites, apps, and services are not targeted towards children. We do not knowingly collect information from children under the age of 16. In some cases, our customers and other individuals provide us information about children for use in connection with us providing services on their behalf. For more information, click here.
  • Under Canadian law, you have the right to access and correct your personal information that you have provided. For information on how to exercise your rights, click here.
  • Our websites use cookies and other automatic data collection technologies. For more information on these technologies and how to configure your preferences, click here. For information about configuring your preference with respect to interest-based advertising, click here.
  • Our websites and apps may contain links to websites owned by third parties. These websites are subject to privacy policies and business practices that we do not control. Users may be able to upload information or content to public areas our websites and apps. We do not control how others may use any such content you may submit.

CONTENTS

  1. ABOUT FIRST CANADA

This section sets out who we are.

  1. when does this privacy notice apply?

This section tells you when this privacy notice applies.

  1. WHAT DO WE MEAN BY PERSONAL INFORMATION?

This section describes what we consider to be personal information for the purposes of this privacy notice.

  1. What TYPES OF information DO we collect?

This section tells you what personal information we may collect from and about you. This includes information that you provide to us directly as well as information we gather through cookies and other automatic data collection technologies and from others.

  1. How DO we collect information?

This section explains the different ways in which will collect information from or about you.

  1. How DO we use information?

This section describes the purposes for which we use personal information we collect from or about you.

  1. DISCLOSURES of PERSONAL information

This section explains who we may disclose your personal information with and why.

  1. Service providers and transfers of personal information outside of Canada

This section explains who we may transfer your personal information to and why. It also explains any transfers of your personal information that we may make outside of Canada.

  1. CONSENT

This section explains when we will obtain consent from you and, to the extent applicable, how you can withdraw your consent.

  1. YOUR CHOICES ABOUT YOUR PERSONAL INFORMATION

This section explains the choices you have with respect to your personal information.

  1. How DO we PROTECT information?

This section explains how we safeguard your information.

  1. data Retention

This section explains how long we will retain your personal information.

  1. Children’s privacy

This section explains our information practices with respect to children.

  1. YOUR RIGHT TO ACCESS AND CORRECT YOUR INFORMATION

This section explains your right to access and correct your personal information and how to go about exercising this right.

  1. Cookies and automatic data collection technologies

This section explains how we use cookies and other automatic data collection technologies.

  1. Interest-based advertising

This section explains how we and others may use interest-based advertising to provide you with advertisements based on your interests.

  1. third party LINKS AND user content

This section explains what happens if you click on third-party links that may be made available within our websites and apps or upload user content.

  1. Changes to our privacy notice

This section describes how and when we will communicate updates of this privacy notice to you.

  1. who CAN YOU CONTACT FOR MORE INFORMATION?

This section explains how to contact us if you have questions or concerns about our privacy practices. It also explains how you can contact our Privacy Officer if you are unsatisfied with our response.

About First Canada

First Canada ULC and its subsidiaries including Autobus Transco (1988) Inc. (“First Canada”, “we”, “us”, “our”)_are doing business provide bus, local transportation, and other mobility services to its customers and their riders and users. Its address is 3455 Landmark Road, Unit #2, Burlington, ON, L7M IT4 CANADA.

At First Canada, we are committed to protecting your privacy by complying with applicable Canadian laws and regulations. As we are a national organization, this privacy notice is designed to meet the standards prescribed by the Personal Information Protection and Electronic Documents Act (PIPEDA) and the regulations thereunder as well as applicable provincial privacy legislation and regulations.

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When does this privacy notice apply?

This privacy notice applies to any personal information we collect about you in relation to our websites, apps, transportation services, mobility solutions, and other services (“Services”) that we operate or provide in Canada.

This notice covers personal information about you that we collect, use, or otherwise process in connection with your relationship with us as a customer, potential customer, rider or other user of our Services including:

  • when you travel with us or otherwise use our Services.
  • when you use our websites and apps that link to this notice.
  • when you call our customer service representatives to purchase tickets or to arrange to use our Services, or to make inquiries about the same, whether you call us directly or someone else calls on your behalf.
  • when you interact with our advertising.
  • when you telephone us or write to us by mail.
  • when you interact with us (or post about us) on or through social media.
  • when you otherwise communicate with us about our Services, including by email, text, and postal mail.

This privacy notice does not apply to the following, which are covered under separate privacy notices:

  • First Canada’s First Student services;
  • First Canada job applicants or employees.


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What do we mean by personal information?

This section informs you of how we define personal information for the purposes of this privacy notice.

Privacy laws in Canada generally define “personal information” as any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person.

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What types of information we collect?

This section informs you of what information we collect about you and when we consider that information to be personal information.

We may collect, use, and disclose different kinds of information, depending on our relationship with you, which we have grouped into the following categories:

  • Identity information includes your first name, last name, username or similar identifier, title, date of birth and gender.
  • Contact information includes billing address, home address, work address, email address and telephone numbers.
  • Financial information includes bank account and payment card details used to purchase Services.
  • Transaction information includes details as to your rides, details about payments related to those journeys, and other details of other Services we have provide to you or that you have purchased from us.
  • Technical information when you access and use our websites and apps, we may collect information about your device and internet connection including your device’s unique identifier, IP address, browser type and version, mobile network information, your device’s telephone number, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our websites and apps.
  • Profile information includes your username and password, records of purchases or orders, interests, preferences, feedback and survey responses.
  • Usage information includes information about how you use our Services.
  • Health information includes information relating to your mobility and disability status to enable us to provide assisted travel and any information detailed within any accident reports that relates to personal injury or receipt of medical attention.
  • Marketing and communications information includes your preferences in receiving marketing from us and third parties and your communication preferences.
  • Demographic information and preferences includes include personal characteristics and preferences, such as your age, transportation-related preferences, data from social media platforms (when you interact with our channels or post about us), education and professional information (for example, when we provide transportation to or from your school or workplace), and ride-related needs and preferences such as whether you need a child car seat when you travel.
  • Location information includes real-time information about the location of your device or a vehicle on which you are known to be a rider. Location information may also include precise geolocation data (latitude/longitude). For example, when you ask us to recommend transportation routes and options, we may use your location information including geolocation data. For more information, see Your choices about your personal information.
  • Audio visual information includes photographs, video images, CCTV recordings, call center recordings and call monitoring records, and voicemails. The information in this category may overlap with other categories.
  • Children’s information may include identity, contact, age, and education-related information. For example, when we provide transportation services on behalf of a customer that is a school, the customer may provide us with the names, addresses, grades, and other ride-related information of the children we are transporting on its behalf. A customer may let us know whether a car seat is needed or if a child has health-related transportation needs. We do not knowingly collect personal information directly from children under 16, except where we have the consent of parents, guardians, or another authorized person or entity. For more information on our collection of data from or about children click here.
  • User content includes include photos, reviews, and other feedback that you provide to us or post on or through our social media pages, websites, or apps. If you choose to provide user content, it may be made available on public areas of our website, apps, or on or through our social media channels.

When information we collect meets the definition of “personal information” under Canadian laws, we will treat it accordingly.

We may also collect, use share, and transfer aggregated and anonymized data, such as statistical or demographic data for any purpose. Neither aggregated nor anonymized data is considered personal information as it does not reveal your identity Examples of aggregated data include where we (1) use your usage information to calculate the percentage of users accessing a specific website feature; or (2) use your transaction information or location information to determine the number of people passing through our transit stations at a particular time of day. If we combine aggregated data with other personal information in a way that results in us being able to directly or indirectly identify you, we will treat this combined data as personal information and in accordance with this privacy notice.

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How do we collect information?

We use different methods to collect your information, including:

When you provide it

We collect information when you provide to us directly. We collect information from you online or in person. For example, we collect information from you when you:

  • Fill in a form on one of our websites, telephone us, or send us an email.
  • Purchase transit tickets or use our Services.
  • Post feedback for display in a public-facing area of one of our websites, apps, or social media channels.

In all of the above cases, you may provide us with information about yourself or about other individuals (such as children or other family members). In these cases, when you supply personal information about these other individuals, you must have previously obtained their consent or otherwise have the legal authority to provide their personal information to us for processing consistent with the relevant purposes described in this privacy notice. If you do not have their consent, or the legal authority, do not provide us with their personal information.

Automatically from our websites, apps, and emails

As you interact with our websites, apps, or emails, we automatically collect technical information and usage information about your equipment, browsing actions and patterns. We may also collect information if you interact with websites owned by others that use our cookies. We collect this information by using cookies, server logs, web beacons, and other similar technologies. See Cookies and automatic data collection technologies for more information about our use of these technologies and how to control or opt-out of certain data collection or uses.

From others

We may also receive personal information about you from third parties such as:

  • Our service providers, when we request that they collect information on our behalf.
  • Our riders (and other users of our services) including, for example, riders who provide us information about family members or persons.
  • Our customers who have outsourced the provision of specific services to us. For example, in some cases we act as a service provider to our customers by providing transportation, mobility, on-demand non-emergency medical transportation, or other services to their customers – and receive personal information about you to fulfil those services.
  • Our business partners with whom we collaborate to provide services to our riders. For example, we may work with a ride-sharing company to present you with multiple transportation options.
  • We may process personal information that you choose to make public, such as when you post about us on social media.
  • Companies or organizations that provide us with data in accordance with their privacy policies and/or in accordance with applicable law.

In all the above cases, we may collect personal information about adults and minors. When we receive information from others, we rely on them to lawfully collect the information from or about you by, among other things, providing you with any required notices and, when required, obtaining your consent.

From closed-circuit television (CCTV)

We use CCTV cameras to capture, record and monitor what takes place at our facilities and on some of our buses and other transit vehicles to help us provide a safe environment for our passengers, employees, and the general public and to prevent, deter and detect crime.

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How do we use information?

We generally use your information, including personal information, for the following purposes:

  • to present, operate, and administer our Services
  • in cases where we offer this option to our customers, to create, maintain, and secure an online account with us.
  • to provide you with information and Services that you request or order from us, including to recommend transportation routes and mobility service options.
  • to determine your eligibility for (and report your use of) our Services according to our contracts with customers, applicable laws and our policies.
  • to process your requests, transactions, and payments and to provide transportation services.
  • to ensure the health, safety and general well-being of riders, customers, employees, and the general public, which may in some cases include collection by way of a video camera placed in a bus or other vehicle.
  • to administer the physical security of the First Canada facilities including transit stations, which may in some cases include collection by way of a video surveillance system.
  • to improve our websites, apps, Services, marketing or customer relationships and experiences. For example, we may use your information to optimize station use, improve operational efficiency, and to increase ridership.
  • to receive, investigate and address inquiries or complaints from riders, customers, and others.
  • to settle insurance claims relating to motor vehicle accidents other incidents involving a First Canada vehicle or employee.
  • to measure or understand the effectiveness of our advertising and to deliver advertising to you.
  • to investigate and respond to legal matters.
  • to carry out our obligations and enforce our rights arising from any contracts with you, including for billing and collection or to comply with legal requirements.
  • to notify you about changes to our website, apps, or Services.
  • for such other purposes as you may consent from time to time.
  • as otherwise required or permitted by law.

We may use location information to recommend transportation routes, mobility service options, and other Services that you request.

We may also use your information to contact you about our services that may be of interest to you, as permitted by law. If you do not want us to use your information in this way, see Your choices regarding your personal information.

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Disclosures of personal information

This section explains who we may share your personal information with and why.

We may disclose aggregated information about our customers, and information that does not identify any individual, without restriction.

We may disclose your personal information that we collect as described in this privacy notice:

  • to our business partners who we work with to coordinate and provide Services to our customers and riders. For example, if you request a ride from a transit stop to your home, we may provide our business partner (e.g., Uber or Lyft) with your information so that our business partner’s driver can provide you with the services that you have requested.
  • to our customers who contract with us to provide transportation, mobility, or other services on your behalf. For example, we may disclose information to a city or transit agency who has contracted with us to provide services or to a customer who has contracted with us to provide on-demand non-emergency medical transportation services to its riders.
  • to third parties who we work with to provide us with online advertising services and other services relating to our websites and applications. These third parties may include advertisers, advertising networks, and other online service providers. For more information, see Cookies and automatic data collection technologies and Interest-based advertising.
  • in accordance with applicable law, to an actual or prospective buyer or other successor in the event of merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by First Canada about our customers and users is among the assets transferred.
  • to fulfill the purpose for which you provide it. For example, if you give us an email address to email your trip itinerary to another person, then we will transmit the contents of your itinerary to that person.
  • for such other purposes as you may consent from time to time.

We may also disclose your personal information:

  • to comply with any court order, law, or legal process, including responding to any government or regulatory request.
  • to enforce our Terms of Use and other agreements with you.
  • if we believe disclosure is necessary or appropriate to protect the rights, property, health, or safety of First Canada, our employees, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
  • to investigate suspected violations of any law, rule or regulation, or the terms or policies for our website.

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Service providers and transfers of personal information outside of Canada

This section explains who we may transfer your personal information to and why. It also explains any transfers of your personal information that we may make outside of Canada.

We may transfer personal information for the purposes described in this notice to our service providers (such as payment processors and analytics providers that assist us with website improvement). In an effort to safeguard your privacy, our service providers are contractually required to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information according to the same standards set out in this notice. In some cases, our affiliated companies may act as service providers to us.

In some cases, Canadian law prohibits us from transferring your personal information outside of Canada. For example, personal information that is regulated by British Columbia’s Freedom of Information and Protection of Privacy Act (BC FOIPPA) may not be stored or accessed from outside of Canada without consent from the individual the information is about (or as otherwise permitted in limited circumstances). In other cases, our contracts prohibit us from transferring personal information outside of Canada. If either case applies, your personal information will remain in Canada. That means that we will keep your personal information at our Canada offices or in the data centres of our service providers located in Canada.

When not prohibited by law or contract, we may process, store, and transfer your personal information in and to a foreign country, with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information through the laws of the foreign country. In such cases, we may keep your personal information at our Canada offices and the offices and data centres of our service providers, who may be in Canada, United States, or United Kingdom.

You may contact us to obtain more information about First Canada’s policies and practices with respect to service providers outside of Canada by writing us at CanadaPrivacy@firstgroup.com or by mailing us at the address set forth below.

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Consent

This section explains when we will obtain consent from you and, to the extent applicable, how you can withdraw your consent.

When First Canada acts as a service provider

In many cases we act as a service provider to our customers. For example, we may provide transit services on behalf of a city, transit authority, or university. In such cases, our customers are responsible for obtaining consent from you unless they have contracted with us to obtain consent on their behalf. If you would like to withdraw consent in cases where we act as a service provider, you should contact the organization to whom you originally provided consent.

When First Canada does not act as a service provider

Unless your consent is not required by applicable law, we generally obtain consent prior to collecting, using or disclosing your personal information.

The form of consent may vary depending on the circumstances and the type of information being requested. Consent can be express or implied and can be provided directly by the you or by an authorized representative. The form of consent that we seek, including whether it is express or implied, will largely depend on the sensitivity of the personal information and the reasonable expectations you might have in the circumstances.

Where you have provided us your consent to the collection, use, and disclosure of your personal information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us at CanadaPrivacy@firstgroup.com. Please note that if you withdraw your consent, we may not be able to provide you with some Services. We will explain the impact to you at the time to help you with your decision.

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Your choices about your personal information

This section explains the choices you have with respect to your personal information. For information on how to exercise rights you may have under Canadian laws see Your right to access and correct your information.

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

  • Promotions. You can opt out of receiving certain promotional communications (emails or text messaging) from First Canada at any time by (i) for promotional e-mails, following the instructions provided in emails to click on the unsubscribe link, or if available by changing your communication preferences by logging onto your account; and (ii) for text messages, following the instructions provided in text messages from First Canada to text the word, “STOP”. Even if you opt out of receiving promotional communications, First Canada may, subject to applicable law, continue to send you non-promotional communications, such as those about your account, transactions, servicing, or First Canada’s ongoing business relations.
  • Accessing, updating and deleting your information. If you have an account with us, you may have the ability to access your information and make updates to or delete your data by logging into your account. If not, you can contact us as set forth in the Your right to access and correct your information section to request access to and correction of personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or negatively affect the information’s accuracy.
  • Cookies and automatic data collection technologies. Information about how to disable or remove cookies is available in the Cookies and automatic data collection technologies section of this notice.
  • Location information. You can choose whether to allow our websites and apps to collect and use real-time information about your device's location by declining to consent to our use of your location information when prompted. After you have consented to our use of your location information and you later change your mind, you can disable our ability to collect your location information through your device's privacy settings. If you block the use of location information, some parts of our websites or apps may become inaccessible or not function properly.
  • Interest-based advertising. Please see Interest-based advertising section for information on how to opt-out of interest-based advertising.

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How do we protect information?

This section explains how we keep your personal information safe.

We use physical, organizational, administrative, contractual and technological security measures designed to protect your personal information from accidental loss and from unauthorized access, use, alternation, and disclosure. We have taken steps to ensure that only employees who are granted access to your personal information are those with a business ‘need-to-know’ or whose duties reasonably require such information. When required by law or contract, we keep personal information on servers that are in Canada.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our websites or apps, you are responsible for keeping this password confidential. We ask you not to share your password with anyone, and to alert us if you believe that password has been compromised.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to us over the internet. You acknowledge that any transmission of personal information is at your own risk.

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Data retention

This section explains how long we will retain your personal information.

Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.

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Children’s privacy

This section explains our information practices with respect to children.

Our websites and apps

Our websites and apps are not intended for children under 16 years of age. No one under age 16 may provide any personal information to us through our websites or apps. We do not knowingly collect personal information from children under 16 through our websites or apps. If you are under 16, do not use or provide any information on this website or any of our apps. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact our Privacy Officer as described in the below.

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Our services

First Canada is a leading provider of transit services to individuals of all ages. In providing services to our customers or riders, we may provide transit services to children, including children under the age of 16. In connection with such services, our customers may in some cases provide us with personal information about the children we are transporting.

When we provide transportation services to children on behalf of our customers or riders, we rely on our customers or riders to comply with any applicable privacy law requirements including, for example, providing any necessary disclosures and obtaining any necessary consents. In some cases, when our customer contract requires, we may provide notices and obtain consents on behalf of our customers. If you have questions about information we have been provided by our customers or riders about children, please contact the organization or person who hired us to provide Services.

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Your right to access and correct your information

This section explains your right to access and correct your personal information and how to go about exercising this right.

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes.

By law you have the right to request access to and to correct the personal information that we hold about you.

How can you access and correct your personal information?

If you have an account with us, you may be able to review and change your information by logging into your account and visiting your account profile or settings page.

If you want to review, verify, or correct your personal information you may also send us an email at CanadaPrivacy@firstgroup.com to request access to, correct, or delete any personal information. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

How do we know that it is really you requesting your personal information?

We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes.

How and when will we respond to your written requests?

We will attempt to respond to each of your written requests within thirty (30) days of receipt of your request. We will advise you in writing if we cannot respond to your request within this timeframe. You have the right to make a complaint to the Privacy Commissioner of Canada or applicable provincial privacy commissioner in respect of this time limit.

We will provide access to your personal information, subject to exceptions set out in applicable privacy legislation. Examples of such exceptions include:

  • Information protected by solicitor-client privilege.
  • Information that is part of a formal dispute resolution process.
  • Information that is about another individual that would reveal their personal information or confidential commercial information.
  • Information that is prohibitively expensive to provide.

If we cannot provide you with access to your personal information, we respond and let you know why, subject to any legal or regulatory restrictions.

If you are concerned about our response or would like to correct the information provided, you may contact our Privacy Officer at CandaPrivacy@firstgroup.com.

Are there any costs to you for requesting information about your personal information or our privacy practices?

We may charge you a fee to access your personal information, however, we will notify you of any fee in advance.

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Cookies and automatic data collection technologies

This section explains how we use cookies and other automatic data collection technologies.

Cookies

Cookies are text files that contain small amounts of information which are downloaded to your personal computer, mobile or other device when you visit a website.

Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognizes that cookie. Cookies are useful because they allow a website to recognize a user's device.

Cookies in themselves do not identify you, just the computer or device you are using. Cookies can also be used to record which areas of our website have been visited by your computer or device and for how long.

We use cookies for several reasons including to:

  • Estimate our audience size and usage patterns.
  • Store information about your preferences including, for example, your language preferences or geographic region, so we may optimize your experience on our website and in our apps.
  • Speed up your searches.
  • Recognize you when you return to our website.
  • Serve you with relevant advertising.
  • Learn more about how you interact with our websites
  • Analyze how well our websites are performing
  • Analyze errors and how to resolve them

Types of cookies we use

These are the types of cookies we use:

  • Strictly necessary cookies. Our website requires the use of these cookies to properly operate or provide necessary functions relating to the services you request. include, for example, cookies that enable you to log into secure areas of our website or make a purchase.
  • Analytics/performance cookies. These cookies allow us and our third-party service providers to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us improve how our website works by, for example, ensuring that users can easily find what they need on our website. We use Google Analytics to provide certain analytics services for us. More information about Google Analytics can be found in the Google Analytics Terms of Use and the Google Analytics Privacy notice. If you do not want Google Analytics to be used in your browser, Google Analytics provides an opt-out tool which can be found here.
  • Functionality cookies. These cookies enable helpful but non-essential website functions that improve your website experience. By recognizing you when you return to our website, they may, for example, allow us to personalize our content for you, greet you by name, or remember your preferences (for example, your choice of language or region).
  • Advertising, tracking or targeting cookies. These cookies enable different advertising-related functions. They may allow us to record information about your visit to our website, such as pages visited, links followed, and videos viewed so we can make our website and/or the advertising that we display to you more relevant to your interests. When you visit other sites on the web, these cookies may be used to let our retargeting providers know when to serve advertisements and what content to show you. These cookies also allow us to know whether you've seen an advertisement, and how long it has been since you've seen it. For more information, see Interest-based advertising.

How to control cookies

With most Internet browsers, you can erase or block cookies or ask to receive a warning before a cookie is stored. The “Help” function within your browser should tell you how. Alternatively, you may wish to visit the following sites which contain comprehensive information on how to do this on a wide variety of browsers:

www.aboutcookies.org
www.allaboutcookies.org

You will also find details on how to delete cookies from your computer as well as more general information about cookies.

Please be aware that restricting cookies may have a negative impact on the functionality of the website or your use of some of our Services.

For information on how to opt-out of cookies used to serve you advertisements, see Interest-based advertising section of this privacy notice.

Other tracking technologies

In addition to cookies, the other technologies we use for this automatic data collection may include:

  • Flash cookies. Certain features of our website may use Flash cookies (local stored objects) instead of browser cookies to collect and store information about your preferences and navigation to, from, and on the website. Tools to block browser cookies on commercial browsers may not be effective on Flash cookies (also known as locally shared objects) or HTML5 cookies. To learn how you can manage your Flash cookie settings, visit the Flash Player Help page on Adobe’s website. Information on how to disable Adobe Flash cookies is available here. Please be aware that if you disable or remove Flash cookies, some parts of the website may not work properly.
  • Web beacons (“tracking pixels”). Our website pages, advertisements, and e-mails may contain small transparent embedded images or objects known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count website page visitors or email readers, or to compile other similar statistics such as recording website content popularity or verifying system and server integrity. In some cases, you may be able to set your browser or email program to not download web beacons
  • Embedded scripts. An embedded script is programming code designed to collect information about your interactions with our website. It is temporarily downloaded onto your computer from our web server, or from a third party with which we work and is active only while you are connected to the website and deleted or deactivated thereafter.
  • Log information. Log information is data about your use of the website, such as IP address, browser type, Internet service provider, referring/exit pages, operating system, date/time stamps, and related data, and may be stored in log files
  • Precise geolocation. We may receive information about your precise location (longitude/latitude) from things like global positioning system (GPS) coordinates (longitude and latitude) when you use our mobile apps. Before we collect your precise geolocation, you will always get a pop-up notice on your phone or device asking for you to accept or reject allowing us to know exactly where you are in the world. You should understand that we will not always ask for consent to know generally that you are in a broader city, postal code, or province. For example, we do not consider it to be precise location if all we know is that you are somewhere in Toronto, Canada.

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Interest-based advertising

This section explains how we and others may use interest-based advertising to provide you with advertisements based on your interests.

First Canada may engage and work with service providers and other third parties to serve advertisements for our Services on our websites and/or on other websites not owned or operated by First Canada. Some of these ads may be tailored to your interests based on your browsing of the website and elsewhere on the Internet, sometimes referred to as “interest-based advertising” and “online behavioral advertising” which may include sending you an ad on a third-party website for our Services after you have left our website (i.e., “retargeting”). Some third parties we work with may use the data they collect on our website (along with other data they collect) for their own benefit or to serve advertisements for products and services of their other customers.

These service providers and third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. They may associate the information they collect with your personal information, location, and/or one or more of your devices. They may also collect in this information about your online activities over time and across different websites and other online services.

You can opt-out of many third-party ad servers’ and networks’ interest-based advertising cookies simultaneously by using the following tools:

  • The Digital Advertising Alliance (DAA) of Canada makes tools available that allow users to opt-out of interest-based adverting’s from its member organizations. It’s opt-out tools are available here.
  • The Network Advertising Initiate (NAI) also has an opt-out platform that is available here.

By using these tools, you can opt out of interest-based advertising from the DAA’s and NAI’s member organizations. You can also access these websites to learn more about online behavioral advertising and how to stop websites from placing cookies on your device.

Please note that if your browsers are configured to reject cookies when you use these opt-out tools, or you subsequently erase your cookies, use a different device or web browser or use a non-browser-based method of access (e.g., mobile app), your NAI and DAA browser-based opt-outs may not, or may no longer, be effective.

Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.

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Third party links and user content

This section explains what happens if you click on third-party links that may be made available within our websites and apps or upload user content.

Third-party links

Our websites may contain links to other sites, which we do not control. Those websites have their own privacy policies and terms.

First Canada is not responsible for, and makes no representations regarding, the policies or business practices of any such social features, user content or links and encourages you to familiarize yourself with and consult their privacy policies and terms of use.

User content

Our websites may allow you to upload your own content to public areas of the website. Any information you submit becomes public information, and we do not control how others may use the content you submit. We are not responsible for uses that may violate our privacy notice, the law, or your intellectual property rights.

Changes to our privacy notice

This section explains how we make changes to our privacy notice.

This privacy notice may change from time to time and, if it does, the up-to-date version will always be available on our website. We will also tell you about any material changes to our privacy notice. If you have an account with us, you are responsible for ensuring we have up-to-date, active and deliverable email address for you and for periodically visiting our website and this privacy notice to check for changes.

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Who can you contact for more information?

All comments, questions, and requests regarding your personal information or our privacy practices should be forwarded to our Privacy Officer as follows:

Mail: Privacy Officer

c/o First Group America, Inc.

191 Rosa Parks Street

Cincinnati, Ohio 45202

USA

Email: CanadaPrivacy@firstgroup.com

We have procedures in place to receive and respond to complaints or inquiries about our handling of personal information, our compliance with this notice, and with applicable privacy laws. To discuss our compliance with this notice please contact our Privacy Officer using the contact information listed above.

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