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Our Privacy Policy

Last Revised: March 16, 2021

INTRODUCTION

RSR Technologies Ltd. (collectively, “RSR Technologies”, “we”, “us” or “our”) are committed to protecting the privacy and confidentiality of personal information in our possession. This Privacy Policy explains how we collect, use and disclose personal information that you provide to us through the RSR Technologies website located at https://roadlee.com (the “Website”) together with the mobile version of the website and the mobile application (the “App”, and collectively, the Website, mobile version and App are the “Service”). Roadlee is a technology platform that enables Registered Users of our Service to obtain roadside assistance from independent third party providers of such services who are under agreement with us (“Third Party Service Providers”).  Unless otherwise defined herein, all defined terms have the same meaning as set out in the Terms of Service.

By accessing or using the Service, you signify your acceptance of this Privacy Policy and consent to be bound by its terms. You can withdraw your consent at any time by contacting our privacy officer as directed below, however, if you choose to withdraw your consent, we may not be able to provide you with the services or communications that are available through the Service.

CHANGES TO THIS PRIVACY POLICY

We reserve the right, at our discretion, to amend this Privacy Policy at any time without prior individual notice. The date on which this Privacy Policy was last amended is shown at the top of this policy. You are responsible for verifying whether any amendments have been made and therefore we ask that you periodically check the date and review this Privacy Policy for the latest information on our privacy practices. If you object to any amendments, please stop using the Service, otherwise your continued use will be taken as your consent to such amendments.

WHERE THIS PRIVACY POLICY IS EFFECTIVE

RSR Technologies is subject to the Personal Information Protection and Electronic Documents Act (Canada) and applicable Canadian provincial privacy legislation.  Privacy laws vary by jurisdiction.  You acknowledge and agree that access to the Service that are available through the Service are provided via the Internet and that your information, including personal information, may be transferred across national borders and stored or processed in accordance with the terms and conditions of this Privacy Policy.

This Privacy Policy has a limited scope and application. Consequently, the rights and obligations contained in this Privacy Policy may not be consistent with privacy requirements for all jurisdictions.

 

WHAT IS PERSONAL INFORMATION?

For the purposes of this Privacy Policy, personal information is any information about or that identifies a specific individual, and under certain laws that may or may not be applicable to you, identifies a specific household or device.

 

 

 

THE PERSONAL INFORMATION THAT WE COLLECT

We collect and maintain different types of personal information in respect of the individuals with whom we interact. This personal information may include, but is not limited to the personal information that is described in the sections below.

Personal information that you provide to us as a Registered User

  • personal contact information for yourself that is used to create an Account with us, such as your name, email address, phone number, home address and a photograph of yourself. Please note that we will use your contact information to send you a SMS verification in connection with the creation of your Account;

 

  • information about your vehicle, including the year, make, and model of the vehicle, an image of the vehicle, and your licence plate number (the “Vehicle Information”);

 

  • personal contact information for a minor for whom you are a parent or legal guardian and are creating a Minor Subaccount (as further described in our Terms of Service), such as the minors name, email address, phone number, home address and a photograph of the minor. Please note that we will use the minor’s contact information to send the minor a SMS verification in connection with the creation of the Minor Subaccount;

 

  • location in connection with your use of the Service. For example, we use your location information to determine your location when you request assistance from a Third Party Service Provider through the Service. You can enter this information manually or allow us to collect this information through the settings in your App;

 

  • transaction information in connection with your use of the Service, which includes the type of service requested, your Responses to any prompts, the date and time the service was provided, the information of the Third Party Service Provider you were matched with, the amount charged and the payment method; and

 

  • personal information that is contained in any customer service inquiry, User Content, in-App communications between you and a Third Party Service Provider, or other communication, including your rating or review from the Third Party Service Provider.

 

You may use your PayPal account or credit card to use the Service. When you create an Account, you will be directed to the Braintree, a division of PayPal, Inc., website to input your credit card information. Please see section on PAYMENT PROCESSING for further details. We are provided with confirmation from our Payment Processors (as defined below) when your transaction has been completed.

 

Personal information that you provide to us as a Third Party Service Provider

  • personal contact information required to register an account as a Third Party Service Provider, such as your name, email address, phone number, and home address, date of birth, signature, and a photograph of yourself;

 

  • business contact information, such as your title, business address, email address, work eligibility, and details relating to your employment;

 

  • information relating to your licences (e.g., driver’s licence), vehicle insurance, permits, qualifications, education, credentials and other experience as required to determine your suitability to provide Vehicle Services, as more particularly described in the Terms;

 

  • Vehicle Information (as defined above);

 

  • payment and banking information, including your account number, institution number, transit number and the email address associated with your bank account for e-transfers;

 

  • location information in connection with your use of the Service, which is used to track your proximity to how close they are to a Registered User, the distance until they arrive to perform the Vehicle Services and how long the Vehicle Services are taking;

 

  • transaction information, including the date and time the service was provided, the distance travelled, the information of the Registered User you were matched with and the amount charged to the Registered User. We will also collect information about the rating or review from the Registered User; and

 

  • personal information that is contained in any customer service inquiry, User Content, in-App communications between you and a Registered User, or other communication, including your rating or review from the Third Party Service Provider.

 

Please note that we may request that you provide more than one piece of identification for the purpose of completing a background check. When you create an Account as a Third Party Service Provider, you will be sent a link to complete your background check, as required in connection with Account creation.

Personal Information that we Receive from Third Parties

As a general rule, we collect personal information directly from you. In most other circumstances where the personal information we collect about you is held by a third party, we will take reasonable steps to ensure that such third party has obtained your permission to disclose your information to us (such permission may be given directly by you, or implied from your actions). From time to time, we may utilize the services of third-parties and may also receive personal information collected by those third-parties in the course of the performance of their services for us or otherwise.

 

OTHER INFORMATION THAT WE COLLECT

For Registered Users, Third Party Service Providers and Visitors

  • Technical and Usage Information

When you visit the Website, web servers automatically collect certain information about your visit to a website, including your Internet Protocol (“IP”) address. IP addresses are unique numbers assigned by Internet Service Providers (“ISP”) to all devices used to access the Internet. Web servers automatically log the IP addresses of visitors to their sites. The IP address, on its own, may not identify you, but can do so when combined with other data automatically collected when you request a web page, such as the name of the page you visited and the date and time of your visit.

When you visit the Website, we may collect technical information, which may include the address of the website that you visited before visiting the Website, the pages of the Website that you visit, the browser you used to view the Website, the search terms you entered on the Website, and other such technical data. 

If you have downloaded and use the App, we also collect access dates and times, App features used, App crashes and other system activity.

  • Cookies

We may also use cookies. Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your web browser (if you allow) that enables the sites or service providers systems to recognize your browser and capture and remember certain information. We use the following Cookies:

  • Functionality Cookies: These cookies allow a website to remember the choices a user has made in the past, like what language the user prefers or what the user’s name and password are so that the user can automatically log in.

 

  • Analytical Cookies: These cookies allow us to recognize and count the number of visitors to our Service and see how visitors move around our Website and Application when they are using it. This helps us improve the way our Service works, for example, by ensuring users are finding what they are looking for easily.

We use cookies to help us remember and process the items in your shopping cart, understand and save your preferences for future visits and compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future. We may contract with third-party service providers to assist us in better understanding our site visitors. These service providers are not permitted to use the information collected on our behalf except to help us conduct and improve our business.

If you prefer, you can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies via your browser settings. Disabling cookies when you visit our Website will have no discernible impact on your browsing experience. Please consult your browser’s Help Menu for instructions.

Like most websites, if you turn your cookies off, some of our services may not function properly.

  • Device Information.

We collect information about the device(s) you use to access our Service, including the hardware models, device IP address, operating systems and versions, software, file names and versions, preferred languages, unique device identifiers, advertising identifiers, serial numbers, device motion information, and mobile network information.

PURPOSES FOR COLLECTION AND USE OF YOUR INFORMATION

We may collect and use personal information for the purposes identified at the time of collection, as otherwise permitted or required by applicable law, or for any of the following purposes:

  • to establish, maintain and manage our relationship with you so that we can provide you with the Service and/or access to our Website;
  • to provide you with the services you have requested through the Service and to facilitate your receipt and/or provision of services as a Registered User or Third Party Service Provider;
  • to understand your preferences and tailor communications and services to you and to send you information about RSR and its partners;
  • to match Registered Users with Third Party Service Providers;
  • to screen Third Party Service Providers to help ensure the safety of Registered Users, including by conducting background;
  • to enable Vehicle Services or other services, including to suggest tow truck drivers and to offer nearby service providers in the event the Registered User needs additional Vehicle Services from a mechanic;
  • to track the progress of the Vehicle Services;
  • to comply with our legal obligations and regulatory requirements;
  • to develop and manage our business and operations;
  • for billing, accounting and debt collection services relating to the Service;
  • to facilitate payment for the use of the Service;
  • to respond to your questions and concerns;
  • to detect and protect us and you from error, negligence, breach of contract, fraud, theft or other illegal activity, and which may include sharing personal information with our insurers;
  • to create aggregate information for analytics purposes, including to analyze the success, effectiveness, usability or popularity of the Service or website;  
  • to resolve disputes or misunderstandings between users;
  • for internal, external and regulatory audit purposes;
  • to correct technical problems and malfunctions related to the Service; and
  • any other reasonable purpose to which you consent.

By consenting to our collection, use and disclosure of your personal information through our Service you allow us to fulfill the purposes for which we collect your personal information. When we collect your information for research and development purposes, we ensure that any information used for our analysis and reports will be de-identified and aggregated in a manner that will not identify you.

 

HOW DO WE USE YOUR PERSONAL INFORMATION?

We may use your personal information:

  • as permitted or required by applicable law or regulatory requirements;

 

  • for the purposes described in this Privacy Policy; and

 

  • for any additional purposes for which we have obtained your consent to use your personal information.

We may use your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.

 

The ways we communicate with you

We will collect your express or implied consent prior to sending you any commercial electronic messages, unless an exception to obtaining your opt-in consent applies under Canada’s Anti-Spam Legislation (CASL). You will have the opportunity to opt-out of receiving commercial electronic messages at any time. In connection with your use of the Service, we may send you transaction and marketing communications, as described below.

 

Transactional Communications

We provide notifications for certain activities relating to your use of our Services. Examples of transaction communications we may send include sending you emails and SMS messages when you create an account, set/change your password, request a service from a Third Party Service Provider, and complete a transaction through the Service. While you may unsubscribe from marketing communications that are sent to you (as described below), you will continue to receive transactional messages from us relating to your use of the Service and your Account.

 

Marketing Communications

With your consent, we may send you news and marketing communications regarding our products and services that are available through the Service and that we believe may be of interest to you. If at any time you would like to unsubscribe from receiving future marketing emails, please contact us at [insert email address], and we will promptly remove you from our marketing correspondence lists. You can also opt-out of receiving marketing communications through the unsubscribe links provided in the marketing messages we send to you.

 

HOW YOUR INFORMATION IS DISCLOSED OR SHARED

How you may share your information

As described above, certain features of the Service allow Registered Users to make some information available to others. Please think carefully about what you share with others.

How we share your information

If you are a Registered User, we will share certain information to Third Party Service Providers who use the Service when you are requesting a service through the Service. We will disclose your location and your rating to potential Third Party Service Providers so that we may match you with a Third Party Service Provider who is in close proximity. We will also disclose your name, your vehicle information and your photo, if uploaded, to the Third Party Service Provider with whom you have been matched. The Third Party Service Provider will also be able to see your rating and any reviews or comments left by other Third Party Service Providers with whom you have interacted.

If you are a Third Party Service Provider, we will share information with the Registered User, including your name, your vehicle information, the image of your vehicle, and your photo, if uploaded. The Registered User will also be able to see your rating and any reviews or comments left by other Registered Users with whom you have interacted.

We may disclose your personal information to our affiliates and our respective employees, contractors, consultants, service providers and other parties who require such information to assist us with managing our relationship with you, including third parties that provide services to us or on our behalf.

We may also disclose personal information of Registered Users or Third Party Service Providers in the following circumstances:

  • as described in this Privacy Policy;
  • to investigate suspected fraud, harassment or other violations of any law, rule or regulation, or the policies for the Service;
  • to meet or comply with any applicable law, regulation, legal process, audit or enforceable request from a government agency or regulatory body;
  • in connection with a bankruptcy proceeding or the sale, merger or change of control of RSR Technologies;
  • in the event of a merger, acquisition sale or reorganization, or the potential thereof, we may disclose information about you to the extent the personal information is necessary to carry on the business or activity that was the object of the transaction. In the event of a completed transaction, notice will be given to affected users; and
  • for any additional purpose for which we have obtained your consent to disclose your personal information.

We do not sell or rent client lists or personal information to others.

We may retain third party service providers, such as cloud storage services discussed below to help us provide the Service to you. We may need to transfer your personal information to these third party service providers. We use contractual means to ensure these providers provide safeguards that are comparable to our own while your personal information is in their possession. These service providers make no independent use of your personal information.

We may engage third party external servers as well as other external services, including cloud services and cloud compatible servers.

We may use third party service providers or cloud hosting located outside Canada. Since we may share your personal information with third parties, as described in this Privacy Policy, your personal information may be collected, used, processed, stored or disclosed outside of your jurisdiction of residence, including in the United States and other countries whose law may not provide for the same level of data protection as where you live. As such, your personal information may potentially be accessible to law enforcement and national security authorities of another jurisdiction which could impact on your rights, such as your right to an effective legal remedy.

By using the Service, you understand and consent to our disclosure of your information outside the jurisdiction in which you live. You understand and consent that if your information is processed in a foreign country, it may be subject to foreign laws and accessible to law enforcement and national security authorities within that jurisdiction. You also acknowledge that we may disclose your information without your consent where permitted by law or regulatory requirements.

 

 

PAYMENT PROCESSING FOR REGISTERED USERS

We use (i) Braintree, a division of PayPal, Inc., (ii) Apple Pay; and (iii) Google Pay as a third party payment processors (collectively, the “Payment Processors”), to process payments made in connection with the Service. The Payment Processors will collect and store payment information and other personal information necessary to process your payment. When you make a purchase using the Payment Processors, you are subject to their respective Privacy Policy and Terms of Use which we encourage you to read.  We are not responsible for how the Payment Processors manage your payment and personal information to process your payment. The privacy policies of each Payment Processor can be found here: (i) Apple Pay; (ii) Google Pay; and (iii) Braintree /PayPal.

 

LINKS TO OTHER WEBSITES

As described in the Terms of Service, our Website and/or Service may contain links to other sites. This Privacy Policy applies only to personal information that we collect, use and disclose. We are not responsible or liable for the privacy practices of third parties, and we strongly recommend that you review a third party’s privacy policy before disclosing any personal information to the third party.

 

RETENTION AND DESTRUCTION OF PERSONAL INFORMATION

We will store personal information collected via the Service only as long as is necessary for the purposes for which the information was collected. Thereafter, we will keep your information for a reasonable time in accordance with our standard procedures to comply with our legal obligations, to resolve disputes, prevent fraud and abuse and to enforce our agreements, or as necessary for archival/audit purposes.

Even if we delete some or all of your personal information, we may continue to create, retain or use aggregated or anonymized data.

 

SAFEGUARDING PERSONAL INFORMATION 

We endeavour to employ commercially reasonable physical, technical, electronic and procedural safeguards that are appropriate based on the sensitivity of the personal information in question. These safeguards are designed to protect personal information under our control against unauthorized access, use, loss, disclosure, copying, modification, disposal or destruction.

Please note that by submitting User Content (as defined in the Terms of Service) that includes personal information on or through the Service, you are choosing to share your personal information with other users (i.e., the public), including as more particularly described in this Privacy Policy and the Terms of Service.

 

ELECTRONIC COMMUNICATIONS

With your express consent, we may send you promotional emails. At any time, you may opt out of receiving such messages by following the unsubscribe instructions in each email. Please note that even if you opt out of promotional emails, we will continue to send you important account-related information.

 

KEEPING INFORMATION ACCURATE / ACCESS AND CORRECTION

It is important that your personal information held by us is accurate and complete so that we can give you better service. We ask that you keep us informed of any changes, such as a change of address, telephone number or email address.

You have the right to access and correct the information we have about you after we have received your written request and authenticated your identity. Subject to legal restrictions or specific rights of refusal, we will inform you of the existence, use and disclosure of personal information relating to you and give you access to that information.

We may charge a reasonable fee for providing information in response to an access request, and, upon request, we will provide an estimate of any such fee upon receiving a request to access information.

Despite our efforts, errors sometimes do occur. If you identify any personal information that is out-of-date, incorrect or incomplete, let us know. If we agree, we will make the corrections and will make reasonable efforts to communicate these changes to other parties with whom we shared the information. 

 

WITHDRAWAL OF CONSENT

At any time, you may terminate your account. Please see our Terms of Service for more details on how to close your account.

Should you choose to close your account, we will be unable to provide or to continue to provide, the Service.

 

CHILDREN’S PRIVACY

You must be at least 18 years of age to become a Registered User. You must be at least 21 years of age to become a Third Party Service Provider.

Please review the Terms of Use for requirements to create a Minor Subaccount. We do not knowingly collect personal information directly from anyone under the age of 18. Information from Minors must be provided by his or her parent or legal guardian.

If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us. If we become aware that we have collected personal information from children, we will take reasonable steps to locate and remove that information from our servers and records.

 

PRIVACY CONCERNS

If you have any questions and concerns relating to our handling of your personal information, please direct them to our privacy officer listed below. We may need to ask you for personal information to verify your identity.

E-mail: privacy@roadlee.com

If, having shared your concerns with us, you are not satisfied with our answers, you may file a complaint with a privacy regulator, such as the Office of the Privacy Commissioner of Canada by mail at 30 Victoria Street Gatineau, Quebec K1A 1H3 or by calling 1 800 282 1376.

**If you choose to communicate with us via email, please be aware that email is not a 100% secure medium for sending any personal or confidential information to us. **