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HOPR BIKE SHARE PROGRAM – CANADA

PRIVACY POLICY

 

LAST UPDATED: July 2, 2019

Our ongoing commitment to protect the privacy and confidentiality of your personal information is addressed in this Privacy Policy.

Our Privacy Policy complies with the applicable requirements of the Personal Information Protection Act (British Columbia), the Personal Information Protection and Electronic Documents Act (Canada), and the Canadian Standards Association Model Code for the Protection of Personal Information.

This Privacy Policy provides information on how we collect, store, use and disclose any personal information provided to us in the course of participating in our public bike share program (the “Bike Share Program”), and/or our membership application process, and during the time that you are a member of the Bike Share Program (your “Membership”).

Personal Information is information about an identifiable individual. It does not include aggregate data from which we have removed personal identifiers. It also does not include your business contact information. For the purposes of your Membership, personal information may include your financial information (such as credit account card numbers) and other personal information that we obtain in order to process your Membership.

The Bike Share Program is a public bike-sharing program operated by CycleHop Corp. Canada (“CycleHop”).

 

Collection of Personal Information

We may, from time to time, collect the following personal information about you:

  • information that establishes your identity (such as your name, address, phone number, date of birth, etc.);
  • information related to your use of the Bike Share Program, including information on your:
    • travel (such as travel paths, time of day and duration of travel, travel stops, etc.);
    • use of mobile apps (such as time of use, types of apps and app functions used, etc.); and
    • extent of use (such as the frequency of your use of the Bike Share Program);
  • information that you provide on your application for Membership or in setting up and managing your Membership account, including information required to confirm and/or establish your eligibility for corporate and community memberships; and
  • information about your financial behavior, including information on your:
    • payment history;
    • type(s) of credit card(s) used; and
    • late payments, and frequency and timing thereof,

(collectively, your “Personal Information”).

We may collect and confirm your Personal Information as part of your application for Membership and throughout the term of your Membership.

 

Use and Disclosure of Personal Information

We may use the Personal Information that we collect from you from time to time for the following purposes:

  • to verify your identity or complete a payment transaction that is authorized by you;
  • to grant you rights to special memberships, including community and corporate memberships;
  • to communicate to you any benefit, feature, service or other information about your Membership and the Bike Share Program;
  • to promote CycleHop related products or services, as well as products or services of sponsors and partners which may be of interest to you;
  • to help us better manage the Bike Share Program and your relationship with us;
  • to send, deliver or display advertising to you via digital channels (including on-line and email); and
  • as otherwise required or permitted by law.

For the above purposes, we may disclose and make your Personal Information available to our employees, affiliates, agents, service providers, insurers and partners who are required to maintain the confidentiality of your Personal Information. For the purposes of this Privacy Policy, affiliates include any entity that we control, controls us, or is under common control with us, and their successors.

We may disclose your Personal Information from time to time for the following purposes:

  • to verify or process your credit or debit card payments in the context of transactions that have been authorized by you;
  • to prevent fraud, such as disclosure to credit reporting fraud checking agencies;
  • to administer insurance claims; and
  • to comply with regulatory, statutory and legal obligations where disclosure is required or otherwise authorized by law.

We may disclose your Personal Information to regulators, government agencies, public bodies or other entities who have a right to issue requests for your Personal Information.

If we sell or buy any business or assets or undergo other business transactions, we may disclose your Personal Information to the prospective counterparty to the transaction, in accordance with applicable law.  Additionally, if we are acquired by or merged with another company, your Personal Information that we hold will be one of the assets transferred to such other company.

 

Third Party Payment Processor

We use a third party payment processing company called Braintree. In collecting payment, Braintree processes your credit card transactions and obtains various information from you, including Personal Information. Stripe provides some or all of the services from systems located within the United States. As such, your credit card and debit card data (“card data”) and Personal Information will be transferred, processed and stored outside of Canada on servers in the United States, and may be subject to disclosure under the laws of the United States and accessible to United States law enforcement and national security authorities.

Braintree may also provide us with information such as your name, credit card type, expiration date, and the last four digits of your credit card number. This information is only used to make single payment requests, or to register you for an ongoing membership plan that requires automatic payments in the future.

 

Consent

Your knowledge and consent are required for the collection, use or disclosure of your Personal Information, except as required or permitted by applicable law. 

By reviewing this Privacy Policy and becoming a member of the Bike Share Program, you expressly consent to the collection, storage, use and disclosure of your Personal Information for the purposes and in the manner set out in this Privacy Policy.

You may withdraw your consent to the collection, storage, use and disclosure of your Personal Information by contacting CycleHop. We may, however, be required to continue to use and disclose your Personal Information for certain contractual and legal obligations.

 

Limiting Use, Disclosure and Retention

We do not use or disclose your Personal Information for any purpose other than the purpose for which it was collected, except with your consent or as required or permitted by applicable law. We retain your Personal Information only as long as necessary to fulfill the purposes for which it was to be used and disclosed, or as required or permitted by applicable law.

 

Accuracy/Correction of Personal Information

We keep your Personal Information as accurate, complete and up-to-date as is necessary and reasonably practical for the purposes for which it is to be used. It is your responsibility to inform us of any changes to your Personal Information that occur during the course of your membership. You may make correction requests to correct inaccuracies in your Personal Information. If such a request is made, we will correct the Personal Information or annotate your file to indicate that the correction request was made.

 

Security and Safeguarding your Personal Information

We protect your Personal Information by using safeguards that are appropriate to the sensitivity of the particular information.

All our employees are informed about our Privacy Policy and their responsibilities to protect your Personal Information.

We use comprehensive security controls to protect your Personal Information against unauthorized access, use, alteration, duplication, destruction or disclosure.

While we do use third party contractors to assist us, we use appropriate contractual measures with those third parties to ensure protection of your Personal Information.

Our servers and IT service providers may be located in jurisdictions outside of Canada, including the United States.  Accordingly, from time to time, your Personal Information may be stored, accessed, or processed in jurisdictions outside of Canada, in which case it may be subject to disclosure under the laws of the other jurisdiction and accessible to the other jurisdiction’s law enforcement and national security authorities.

 

Changes to our Privacy Policy

We reserve the right to change this Privacy Policy from time to time.

 

Collection Through Our Website

When you visit the CycleHop website, whether or not you are a member, we will collect your internet protocol (IP) address. We also use cookies to identify you as a return visitor and allow you to personalize our website to reflect your preferences and to store Personal Information that you have voluntarily provided through the website. We may also collect information such as the web browser used to access our website, and other information on a consolidated basis for statistical and survey purposes. Some of your Personal Information may also be used to deliver partner and product information based upon your preferences.

We cannot guarantee the confidentiality or security of any e-mail communications or information sent by you to us via our website.  If you wish to send us confidential information, please notify us first to make arrangements.

 

Communication and CASL

We may communicate with you in various ways, including by telephone, email, your Membership account or mail, or by using the contact information you have provided. If we are communicating with you by phone, we may record calls for quality assurance.

Upon registering to become a member of the Bike Share Program, you must expressly agree or disagree to receive Commercial Electronic Messages (“CEM”) from us. CEMs include emails, messages to social networking accounts, and text messages. If you agree, you may still withdraw your consent to receive CEMs from us at any time by unsubscribing using the process provided in the electronic message itself, or by contacting us.

 

Contact Us

Please direct any questions or complaints regarding our handling of your Personal Information, or any other questions about this Privacy Policy, to [email protected].