PRIVACY POLICY

Last Updated: January 19, 2024

The Ontario Transit Group (the “OTG”) has created this privacy policy (“Privacy Policy”) in order to demonstrate our commitment to your online privacy. The following describes our practices for collecting, using, and disclosing personal information, including without limitation on the OTG websites we link to this policy and any other collections of personal information that we link to this Privacy Policy (collectively, the “Sites”).

By using a Site, or by choosing to submit personal information to OTG, you signify your consent to all of the terms of this Privacy Policy. If you do not agree with any terms of this Privacy Policy, please do not use the Site or submit any personal information to OTG.

Please note that when you access any external links from OTG’s Sites (including any OTG subsidiary Sites), they may have different privacy policies specific to those third-party websites. We are not responsible for such third-party websites, and we encourage you to read all privacy policies posted on the third-party websites that you visit.

1.Definition of Personal Information

This Privacy Policy applies to any personal information we collect or receive about you, from you or any other source. “Personal information” as used in this Privacy Policy refers to any information that identifies, relates to, describes, or is reasonably capable of being associated with a particular individual and that is recorded in any form (such as your name, your phone number, and your email address). It may also include technical information such as your IP address, browser settings and device ID, but only when this information can identify you as an individual. Please note that personal information excludes information that is anonymized and cannot be associated with an identifiable individual and aggregate information which represents compiled data from a group of individuals who can no longer be individually identified.

2.Personal Information Collection

The personal information OTG collects directly from you depends on how you use our Sites. OTG generally collects personal information when you browse a Site or interact with us directly, as deemed necessary for the purposes defined in this Privacy Policy. For example:

Personal identifiers. OTG may collect personal information like your name, e-mail address, and any information you provide to us when you make an inquiry or contact us through a Site.
Technical information. We may collect and store information such as the referral URL, IP address, domain name, your general geographic location, your browser type, the pages you view, the links you click, the time and date of access, the length of time you visit our Sites, and other information.

3.Your Choices and Rights

Changing your browser settings on your device. Through technologies such as cookies, our Sites recognize you when you use or return to them and can provide you with a seamless experience. You may be able to set your browser settings to use a Site without cookies ‎functionality. ‎Please note that if you block cookies, some services functions and Sites may ‎be ‎unavailable. Your browser may provide you with some options regarding ‎cookies. For more detailed ‎information about how to disable or administer your ‎cookie settings in your web browser, please ‎refer to the applicable page for the ‎browser you are using.‎

You can withdraw your consent to allow for cookies, change your browser settings, ‎and delete ‎the cookies already stored on your computer at any time. Please note ‎that if you delete, or choose ‎not to accept, cookies, you may not be able to utilize ‎the features of the services on a Site ‎to their fullest potential.

4.Our Use and Disclosure of Your Personal Information

Uses of Personal Information. OTG may use personal information to operate our business, to contact you and respond to your inquires or complaints, to improve our Sites, and for legal, safety, and security purposes, including to protect our rights, property and safety and those of our employees, customers and the public and to detect and prevent fraud.

We use cookies and related tools for capturing Usage Information (collectively “Tracking Technologies”) for the following purposes:

Strictly Necessary. We may use cookies or other Tracking Technologies that we consider ‎are strictly necessary to allow you to use and access our Site, including cookies ‎required to prevent fraudulent activity and improve security.‎
Performance Related. We may use cookies or other Tracking Technologies that are useful ‎in order to assess the performance of our web services, including as part of our analytic ‎practices or otherwise to improve the content or services available on our web services.‎
Functionality Related. We may use cookies or other Tracking Technologies that are ‎required to offer you enhanced functionality when accessing our web services, including in terms of the presentation of content on our Site.‎

OTG may use personal information to create anonymized or aggregated data which does not identify you or any other individual. We reserve the right to provide non-personal identifying information, such as aggregate data, to third parties. We may also use non-personal aggregate information to improve our Sites, or for any other purpose we deem appropriate. For example, our Internet Service providers may report to us that there were a particular number of visitors to a certain area of our Sites. Such information may also be used to analyze the effectiveness of our business models.

We may use personal information to evaluate potential improvements or other modifications to the functionality of our websites. When required by law, we will use anonymized information for these purposes.

Disclosures. OTG may use or disclose your personal information as is necessary to: (a) comply with a subpoena or court order; (b) cooperate with law enforcement or other government agencies; (c) establish or exercise our legal rights; (d) protect the property or safety of our company and employees, contractors, vendors, suppliers, the public and customers; (e) assert or defend against legal claims; (f) help with internal and external investigations; (g) to complete a business transaction or in the context of a prospective transaction, such as a transfer of assets or shares or merger, in accordance with applicable legal requirements, or (g) as otherwise required by law or permitted by law. We may disclose your information in connection with the sale or merger of a OTG company or any transaction that involves the sale or assignment of some or all of our assets.

5.Data Storage and Security

OTG has implemented physical, technical, and administrative security measures to assist with safeguarding your personal information in our possession, and to help protect against unauthorized access and disclosure. Only our authorized personnel and those of our service providers who perform legitimate business functions for OTG are authorized to access your personal information.

We maintain policies and practices which ensure the protection of your personal information. Depending on the volume and sensitivity of the information, the purposes for which it is used and the format in which it is stored, we implement a combination of measures to protect your personal information.

Notwithstanding our efforts, the Internet has inherent security risks. OTG cannot promise, and you should not expect, that your personal information, personal searches, and other communications will always remain secure. You should take care with regard to how you handle and disclose your personal information.

6.Transfers Outside Canada

Some or all of the personal information we collect may be stored, accessed or processed on servers located outside your jurisdiction of residence (for example, outside your province or outside Canada, such as in the United States or Europe), whose data protection laws may differ from the jurisdiction in which you live. As a result, this information may be subject to access requests from governments, courts, or law enforcement in those jurisdictions according to laws in those jurisdictions.

By providing us with personal information, you understand and expressly agree that we may transfer it outside of Canada or your jurisdiction of residence. If you do not agree to the transfer of your personal information outside of Canada, do not provide us with personal information.

7.Children and Data Collection

OTG’s Sites are general audience Sites. OTG’s Site content is not directed toward children who are under the age of 14. We do not knowingly collect personal information from children or minors. If OTG becomes aware that a child has provided us with personal information without parental consent, that information will be deleted from our databases. If you have questions about personal information that may have been submitted by your child, please contact us as indicated in the Privacy Support Contact section below.

8.Accessing and Correcting your Personal Information.

You may request access to your personal information and to request a correction to it if you believe it is inaccurate, incomplete or no longer up to date, subject to limited exceptions set out in applicable laws.

Depending on the law applicable in the jurisdiction where you reside and subject to legal or contractual restrictions, you may also be entitled to:

request that we stop or restrict processing your personal information.
request information on automated processing of your personal information. You can obtain information on the personal information used to render the decision (and request that this information be correct) and the reasons, principal factors and parameters that led to the decision.
obtain a copy of the personal information we collected from you.
obtain additional information about data processing, including the personal information collected and how it is processed by OTG.

To submit a request, please contact us through the Privacy Support Contact. We may require you to verify your identity before processing your request.

9.Data Integrity and Retention

OTG will only process personal information in a way that is compatible with and relevant for the purpose for which it was collected or authorized by you. To the extent necessary for those purposes, OTG will take reasonable steps to ensure that personal information is accurate, complete, current and reliable for its intended use.

Please note that we will only retain your personal information for as long as reasonably necessary for the above purposes or as required by law. Once no longer required, your personal information will be securely destroyed or anonymized, in compliance with applicable laws.

10.This Privacy Policy May Change

OTG may update this privacy policy from time to time, and you should take the time to review it each time that you visit one of our Sites. The privacy policy is current as of the date which appears at the top of this page. By using one of our Sites or providing us with personal information after we update this privacy policy, you agree to this privacy policy as revised. If the changes we make are significant, we will provide a more prominent notice and obtain consent when required by applicable laws. If you do not agree to the changes in our privacy policy, it is your responsibility to stop using our Sites. It is your obligation to ensure that you read, understand and agree to the latest version of the privacy policy.

11.Privacy Support Contact

OTG is committed to protecting your personal privacy. If you have questions or comments about our efforts to protect your personal privacy, or if you require additional information about OTG’s privacy commitment or practices, please contact us at contact@ontariotransitgroup.com.

2023 Ontario Transit Group