VETS CAB PRIVACY POLICY

Privacy at a Glance

Our commitment

Vets Cab collects only the personal information reasonably needed to provide, support and protect taxi, delivery,

account, app, website and dispatch services. We do not sell or rent passenger personal information.

What we collect

Why we collect it

Contact and account details; pickup, destination and trip

records; location information; payment and receipt

information; communications; app, website and device data;

and safety or incident information.

To book, dispatch, complete and bill for services;

communicate with passengers and drivers; support

customer accounts; improve service; maintain safety and

security; investigate incidents; and meet legal, regulatory,

insurance and accounting obligations.

Who receives it

Authorized Vets Cab personnel, affiliated drivers and vehicle

operators, iCabbi and other service providers, payment

processors, account customers, insurers, professional

advisers, regulators and law-enforcement bodies where

permitted or required.

Your choices

You may control app permissions and marketing

preferences, withdraw consent where legally available, and

request access to or correction of your personal information.

Retention

We keep information only as long as reasonably necessary

for the identified purposes and applicable legal, accounting,

regulatory, claim and dispute requirements.

Questions or complaints

Contact the Vets Cab Privacy Officer at the address or

telephone number listed in section 15, or through the

Contents

1. Who We Are and Accountability

2. Scope of This Policy

3. Personal Information We Collect

4. How We Collect Personal Information

5. How We Use Personal Information

6. Consent and Your Choices

7. How We Share Personal Information

8. Drivers, Vehicle Owners and Other Operators

9. Cameras, Audio and Vehicle Technology

10. Processing Outside Ontario or Canada

11. Retention and Disposal

12. Safeguards and Privacy Incidents

13. Access, Correction and Complaints

14. Website, App, Cookies and Third-Party Links

15. Changes and Contact Information

Appendix A. Management Confirmation Checklist

VETS CAB PRIVACY POLICY

1. Who We Are and Accountability

Vets Cab is the operating name of Windsor Airline Limousine Services Ltd. In this policy, “Vets Cab,” “we,” “us”

and “our” refer to that organization and, where the context requires, its authorized personnel acting on its behalf.

Vets Cab is accountable for personal information under its control. We have designated a Privacy Officer to

oversee our privacy program, respond to questions and complaints, and coordinate requests for access or

correction.

This policy is intended to reflect the Personal Information Protection and Electronic Documents Act (“PIPEDA”) and

other applicable Canadian privacy, consumer-protection, electronic-commerce and anti-spam requirements. It

does not limit any rights or obligations imposed by law.

2. Scope of This Policy

This policy explains how Vets Cab collects, uses, discloses, protects and retains personal information in

connection with:

•

taxi, delivery, courier, account and related services;

bookings made by telephone, mobile application, website, web-booker, text message, email, in person or

through an authorized third party;

•

the Vets Cab passenger application, website and other digital services;

customer service, receipts, complaints, lost-property inquiries, incident investigations and insurance claims;

and

•

cameras, telematics or other safety and operational technology used in vehicles or at Vets Cab premises,

where applicable.

This customer-facing policy does not fully describe how Vets Cab handles personal information about employees,

applicants, drivers, vehicle owners or contractors in their working or commercial relationship with Vets Cab.

Separate notices, agreements and internal policies may apply to those individuals.

3. Personal Information We Collect

The information we collect depends on how a person uses our services. We may collect the following categories of

personal information:

3.1 Identity and contact information. Name, telephone number, email address, mailing address, account

username, customer or corporate account identifier, and authentication or account-recovery information.

3.2 Booking, trip and location information. Pickup and destination addresses, current or precise location when

location services are enabled, requested pickup time, booking and dispatch status, assigned vehicle and driver,

route and trip progress, distance, duration, fare, cancellation information, and booking notes or instructions.

3.3 Accessibility, accommodation and safety information. Information voluntarily provided to arrange an

accessible vehicle, mobility assistance, a child seat, assistance for a vulnerable passenger, a safe pickup, or

another accommodation. This may reveal sensitive information, and we limit its use to the purpose for which it was

provided unless otherwise permitted or required by law.

3.4 Payment and transaction information. Fare amount, payment method, payment status, receipts, refunds,

tips, account charges, billing contact details, and limited payment-card or token information received from

payment processors. Payment-card information may be collected directly by a payment service provider under its

own privacy and security practices.

3.5 Communications and service information. Telephone calls and, where notice is provided, call recordings;

emails; text and app messages; customer-service notes; complaints; ratings or feedback; lost-property reports;

and communications with drivers, dispatchers or account administrators.

VETS CAB PRIVACY POLICY

3.6 Device, app and website information. Internet Protocol address, device and advertising identifiers where

enabled, operating system, app version, browser type, language, time zone, log-in and activity records, pages or

features used, referring pages, cookies or similar technologies, diagnostic information, crash reports and security

logs.

3.7 Safety, incident and claims information. Information about collisions, injuries, disputes, suspected fraud,

threats, unsafe conduct, property damage, insurance matters, witness accounts and related photographs, video,

audio or documents.

3.8 Camera, telematics and vehicle information. Where a vehicle or Vets Cab premises is equipped with

disclosed technology, images or recordings, date and time, vehicle location, direction of travel, speed or driving

events, emergency activations and other safety or operational data. Section 9 provides additional details.

3.9 Information about bookings made for another person. A family member, caregiver, hotel, hospital, business,

social-service agency or other person may provide a passenger’s name, telephone number, pickup details,

destination, accessibility requirements or other booking information. The person making the booking should have

authority to provide that information.

Vets Cab does not generally require a passenger’s date of birth, gender, government identification number or

medical diagnosis to provide ordinary taxi service. We will not request sensitive information unless it is reasonably

necessary for a specific service, safety, legal or claim-related purpose.

4. How We Collect Personal Information

We collect personal information:

•

directly from passengers, customers, account holders and people who make or manage bookings;

automatically through the App, website, web-booker, dispatch platform, cookies, logs, location permissions

and connected vehicle systems;

•

from drivers, vehicle operators, dispatchers and customer-service personnel in the course of providing or

supporting a service;

from service providers such as iCabbi, payment processors, telecommunications providers, website hosts and

technical-support providers;

from businesses, hotels, healthcare facilities, community agencies or other organizations arranging or paying

for transportation; and

from insurers, law-enforcement bodies, regulators, witnesses, legal advisers and other sources in relation to

incidents, claims, complaints or legal obligations.

5. How We Use Personal Information

Vets Cab may use personal information for the purposes identified at or before collection and for other purposes

that are reasonably related or permitted by law, including to:

•

create, maintain and secure customer or corporate accounts;

accept, confirm, dispatch, modify, monitor, complete or cancel bookings;

provide a driver with the information reasonably necessary to locate and transport the passenger or complete a

delivery;

•

estimate arrival times, communicate service updates and allow a passenger or account holder to track trip

progress;

•

calculate fares, process payments, issue receipts, administer credits or refunds and collect amounts owing;

provide accessible or otherwise requested accommodations;

respond to questions, complaints, feedback, lost-property inquiries and service issues;

protect passengers, drivers, employees, property, systems and the public; prevent fraud and misuse; and

respond to emergencies;

VETS CAB PRIVACY POLICY

•

investigate collisions, safety events, disputes, complaints, legal matters and insurance claims;

operate, maintain, troubleshoot, secure and improve the App, website, dispatch system, telephone systems

and other services;

•

produce aggregated or de-identified analytics, operational reports and service-performance information;

administer business and institutional accounts and provide authorized account holders with booking, billing or

trip information;

•

meet licensing, transportation, tax, accounting, insurance, court, regulatory and law-enforcement

requirements; and

send service-related messages and, where consent or another legal permission exists, promotional

communications.

No sale of passenger information

Vets Cab does not sell or rent identifiable passenger personal information to data brokers, advertisers or other third

parties for their own marketing purposes.

6. Consent and Your Choices

Vets Cab obtains consent appropriate to the sensitivity of the information and the reasonable expectations of the

individual. Consent may be express or implied by the circumstances, except where collection, use or disclosure

without consent is permitted or required by law.

A person may decline to provide optional information or withdraw consent to certain uses by contacting Vets Cab.

Withdrawal will not affect uses already lawfully made and may be subject to legal, contractual, safety, claim, billing

or record-retention requirements. If information is necessary to provide a requested service, withdrawing consent

may mean that we cannot provide that service in the same manner.

6.1 Location permissions. App users may control location permissions through their device settings. Disabling

precise location may limit automatic pickup detection, live tracking or other location-dependent features; a pickup

address can generally be entered manually.

6.2 Notifications and service messages. Users may control push-notification permissions through device

settings. Transactional messages necessary to confirm or complete a booking may still be sent using the contact

information provided.

6.3 Marketing. Vets Cab will send commercial electronic messages only with consent or as otherwise permitted by

Canada’s Anti-Spam Legislation. Marketing messages will identify Vets Cab and provide a method to unsubscribe.

Service, safety, billing and account messages are not marketing messages.

6.4 Account deletion. A user may request closure of an App or customer account. Some information may be

retained after closure where reasonably necessary for transactions, legal obligations, claims, security, dispute

resolution or other permitted purposes.

7. How We Share Personal Information

Vets Cab may disclose or transfer personal information only as reasonably necessary for the identified purposes or

as permitted or required by law. Recipients may include:

7.1 Drivers and vehicle operators. The driver or vehicle operator assigned to a booking may receive the

passenger’s first name or account identifier, telephone contact function, pickup and destination details, booking

instructions, accessibility information and other information reasonably necessary to complete the service safely.

7.2 Dispatch, customer-service and authorized personnel. Vets Cab personnel may access personal

information on a need-to-know basis to provide, administer, support, secure and improve the services.

VETS CAB PRIVACY POLICY

7.3 Technology and operational service providers. We use third parties to provide dispatch, passenger-app,

web-booking, hosting, cloud, telecommunications, text messaging, mapping, analytics, cybersecurity, technical

support and related services. In particular, Coolnagour Limited, operating as iCabbi, provides core booking and

dispatch technology. Service providers are expected to use information only for authorized services and to protect

it through contractual or other appropriate safeguards.

7.4 Payment and financial service providers. Payment processors, card networks, banks, fraud-prevention

providers and account administrators may process payment and transaction information.

7.5 Business and institutional account customers. Where a ride or delivery is booked or paid for through a

business, government, healthcare, hotel, community or other account, Vets Cab may provide the account holder

with information reasonably necessary to verify, administer and bill the service, subject to the account

arrangement and applicable law.

7.6 Insurers, advisers and claim participants. Insurers, adjusters, lawyers, accountants, auditors, investigators,

repair facilities, medical or emergency responders, and other participants may receive information reasonably

necessary to assess or resolve an incident, complaint, claim or legal matter.

7.7 Government, regulators and law enforcement. We may disclose information to the City of Windsor,

transportation or licensing authorities, courts, law-enforcement bodies, emergency services or other public

authorities where required or authorized by law, legal process, regulatory obligation, emergency circumstances or

a lawful investigation.

7.8 Business transactions. Personal information may be disclosed under confidentiality protections in connection

with a proposed or completed financing, reorganization, merger, sale, transfer or other business transaction, as

permitted by law.

7.9 With consent. We may disclose information to another person or organization when the individual directs us or

provides consent.

8. Drivers, Vehicle Owners and Other Operators

Taxi services may be provided by drivers or vehicle owners affiliated with the Vets Cab brokerage. Depending on the

circumstances, those operators may be employees, contractors, licensees or independent businesses. Vets Cab

limits the booking information made available to operators to what is reasonably necessary to perform, document

and protect the service.

Operators are expected to protect passenger information, avoid using it for personal or unrelated purposes, and

comply with applicable laws, brokerage requirements and confidentiality obligations. A passenger who believes a

driver has misused personal information should contact the Vets Cab Privacy Officer promptly.

9. Cameras, Audio and Vehicle Technology

Some Vets Cab vehicles or premises may use clearly disclosed cameras, emergency systems, telematics or other

safety technology. The exact equipment may vary by vehicle and over time. Notice may be provided by signage in or

on the vehicle, at the premises, in the App, or through another appropriate method.

Where used, these systems may collect interior or exterior video, still images, audio where specifically disclosed,

vehicle location, date and time, speed, braking or other driving events, and emergency activations. Vets Cab may

use this information to protect passenger and driver safety, deter and investigate misconduct or fraud, respond to

emergencies, review complaints, improve training and safety practices, and support insurance or legal matters.

Access is restricted to authorized persons with a legitimate need. Routine recordings are retained for a limited

operational period and may be preserved longer when connected to an incident, complaint, claim, legal hold or

regulatory request.

VETS CAB PRIVACY POLICY

Vets Cab does not use passenger facial-recognition or biometric-identification technology unless it provides a

separate, clear notice and obtains any consent required by law.

10. Processing Outside Ontario or Canada

Vets Cab and its service providers may process or store personal information outside Ontario or outside Canada.

This may occur when we use cloud, dispatch, payment, communications, mapping, analytics or support providers

operating in other jurisdictions.

Personal information processed in another jurisdiction may be subject to the laws of that jurisdiction and may be

accessible to courts, law-enforcement bodies or other authorities in accordance with those laws. Vets Cab

remains accountable for personal information transferred to a service provider for processing and uses contractual

or other measures intended to provide a comparable level of protection appropriate to the information and service.

A person may contact the Privacy Officer for information about service providers or the jurisdictions in which a

specific category of personal information may be processed, subject to security and confidentiality limitations.

11. Retention and Disposal

Vets Cab retains personal information only as long as reasonably necessary to fulfill the identified purposes and

meet legal, regulatory, accounting, tax, insurance, safety, security, claim and dispute-resolution requirements.

Retention periods vary by category and circumstances. For example, account information may be retained while an

account remains active and for a reasonable period afterward; booking, transaction, billing and claim-related

information may be retained for several years; and routine call recordings, security video or vehicle recordings are

generally kept for a shorter operational period unless they are associated with an incident or another reason for

preservation.

When information is no longer required, Vets Cab will destroy, erase or de-identify it using methods appropriate to

its sensitivity and format. Information that is the subject of an access request, complaint, investigation, litigation

hold or legal requirement may be retained until the matter and any available recourse are complete.

12. Safeguards and Privacy Incidents

Vets Cab uses administrative, technical and physical safeguards appropriate to the sensitivity, amount, format and

location of the personal information. Safeguards may include:

•

privacy and confidentiality policies, training and designated accountability;

role-based or need-to-know access controls and user authentication;

secure system configuration, monitoring, backups, encryption or tokenization where appropriate;

physical controls for offices, records and devices;

service-provider due diligence and contractual privacy and security requirements;

incident-response, business-continuity and secure-disposal procedures; and

periodic review of privacy and security practices.

No system can be guaranteed completely secure. If Vets Cab becomes aware of a loss of, unauthorized access to,

or unauthorized disclosure of personal information, we will investigate, contain and remediate the incident. We will

notify affected individuals and report to the Office of the Privacy Commissioner of Canada where required by

PIPEDA, including when a breach creates a real risk of significant harm. We will maintain breach records as

required by law.

VETS CAB PRIVACY POLICY

13. Access, Correction and Complaints

13.1 Access. Subject to legal exceptions, an individual may request access to personal information Vets Cab holds

about them and information about how it has been used or disclosed. Vets Cab may need to verify identity and

clarify the request. We will respond with due diligence and generally within 30 days, unless a permitted extension

applies. Access will normally be provided at no or minimal cost, and any proposed fee will be explained in advance.

13.2 Correction. An individual may ask Vets Cab to correct inaccurate or incomplete personal information. Where

appropriate, we will amend the information and may communicate the correction to relevant recipients.

13.3 Limits. Access may be restricted where disclosure would reveal personal information about another person,

confidential commercial information, information protected by legal privilege, information generated in a formal

dispute-resolution process, or information that cannot lawfully be disclosed. Where possible, Vets Cab will sever

protected information and provide the remainder. If we refuse a request, we will explain the reason to the extent

permitted by law and identify available complaint options.

13.4 Complaints. A person may challenge Vets Cab’s compliance by contacting the Privacy Officer. We will

investigate and respond to privacy complaints in a fair and timely manner. If the concern is not resolved, the person

may contact the Office of the Privacy Commissioner of Canada at priv.gc.ca.

14. Website, App, Cookies and Third-Party Links

14.1 Cookies and similar technologies. The Vets Cab website and digital services may use essential cookies,

local storage, analytics tools and similar technologies to operate the site, remember preferences, measure usage,

diagnose problems and protect security. Browser or device settings can be used to control some technologies, but

disabling them may affect functionality.

14.2 App permissions. The App may request permissions such as location, notifications, telephone or device

functions when needed for a feature. Permissions can be reviewed or changed through device settings.

14.3 Aggregated and de-identified information. Vets Cab may use and share information that has been

aggregated or de-identified so that it is not reasonably capable of identifying an individual, including for service

planning, analytics and reporting. We will not attempt to re-identify such information except for security testing or

as permitted by law.

14.4 Third-party services and links. The App or website may link to services operated by other organizations, such

as mapping, payment, app-store or social-media services. Those organizations have their own privacy practices.

This policy applies only to personal information under Vets Cab’s control.

15. Changes and Contact Information

Vets Cab may update this policy to reflect changes in services, technology, legal requirements or privacy practices.

The current version will be posted on the Vets Cab website and may also be made available through the App.

Material changes will be highlighted or otherwise communicated where appropriate. The “last updated” date will

show when the policy was most recently revised.

Questions, access or correction requests, consent withdrawals and complaints should be directed to:

Title

Privacy Officer

Organization

Mail

Vets Cab / Windsor Airline Limousine Services Ltd.

350 Tuscarora Street, Windsor, Ontario N9A 3L7

519-256-1868 (Front Office)

Telephone

Online