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.
CONTENTS
This section sets out who we are.
This section tells you when this privacy notice applies.
This section describes what we consider to be personal information for the purposes of this privacy notice.
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.
This section explains the different ways in which will collect information from or about you.
This section describes the purposes for which we use personal information we collect from or about you.
This section explains who we may disclose your personal information with and why.
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.
This section explains when we will obtain consent from you and, to the extent applicable, how you can withdraw your consent.
This section explains the choices you have with respect to your personal information.
This section explains how we safeguard your information.
This section explains how long we will retain your personal information.
This section explains our information practices with respect to children.
This section explains your right to access and correct your personal information and how to go about exercising this right.
This section explains how we use cookies and other automatic data collection technologies.
This section explains how we and others may use interest-based advertising to provide you with advertisements based on your interests.
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.
This section describes how and when we will communicate updates of this privacy notice to you.
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.
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.
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:
This privacy notice does not apply to the following, which are covered under separate privacy notices:
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.
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:
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.
We use different methods to collect your information, including:
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:
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.
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.
We may also receive personal information about you from third parties such as:
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.
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.
We generally use your information, including personal information, for the following purposes:
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.
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:
We may also disclose your personal information:
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.
This section explains when we will obtain consent from you and, to the extent applicable, how you can withdraw your consent.
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.
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.
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:
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.
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.
This section explains our information practices with respect to children.
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.
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.
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.
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.
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.
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:
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.
We may charge you a fee to access your personal information, however, we will notify you of any fee in advance.
This section explains how we use cookies and other automatic data collection technologies.
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:
These are the types of cookies we use:
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.
In addition to cookies, the other technologies we use for this automatic data collection may include:
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:
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.
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.
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.
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.
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.
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.