Effective June 20, 2017.
This Privacy Policy describes the practices of eBrake Technologies Inc. (“eBrake”,“we”,“us”, “our”) with respect to our collection, use, storage and disclosure of Personal Information (as defined herein) about you in connection with your use of the EBrake application (the “EBrake App”) and EBrake website located at www.eBrake.ca (the “EBrake Website” and together with the EBrake App, collectively referred to herein as the “EBrake Services”).
This Privacy Policy supplements any agreement you already have with EBrake, including but not limited to, the EBrake End User License Agreement (the “EULA”). This Privacy Policy does not replace the terms of the EULA. By agreeing to the terms of the EULA and by downloading and using the EBrake Services, you are consenting to our collection, use and disclosure of your Personal Information in accordance with this Privacy Policy.
“Personal Information” means information about an identifiable individual, including but not limited to, a first and last name, date of birth and an email address.
We collect Personal Information when you voluntarily provide it to us or use the EBrake Services. You are not obligated to provide your Personal Information, however we may not be able to provide you with access to the EBrake Services, or portions of the EBrake Services, without that Personal Information.
In connection with your use of the EBrake Services, we may collect and store Personal Information that you submit through the EBrake Services, as well as information about your use of and activities on the EBrake Services. Among the Personal Information we collect, please note the following:
a) Your Account. We may collect the Personal Information that you provide to us in the course of registering for a user account for the EBrake App. This information may include, but is not limited to, your name, email address, gender, age bracket and other related demographic information about you.
b) Location. The EBrake Services may require your geographic location. For example, when you turn on the EBrake App, time stamped GPS coordinates may be collected and stored to provide us with location related data, including but not limited to, the time of travel, mileage, speed traveled and route taken (collectively, “Location Data”). Location Data may also be collected by the EBrake Services to provide and tailor promotions and contests that are specific to your geographic location.
c) Mobile Distractions. In addition to location related data, the EBrake App may collect and store data concerning the amount of mobile distractions that occur while you are driving, including but not limited to, how many texts, calls and alerts were blocked while you were driving and the length of time you drove without any mobile distractions (collectively, “Mobile Distractions Data” and together with Location Data, referred to herein as “Distracted Driving Data”).
d) Your Activity. We may collect and store information about how you use the EBrake Services, such as the pages you visit from within the EBrake Website or EBrake App, and the date and time of your access to the EBrake Services.
e) Your Hardware. We may collect and store information about your computer or mobile device, including the type of device, web browser information and referring URLs, mobile carrier, IP address, Bluetooth connection, location data and compass information, unique device or account identifier.
f) IP Address. We collect and analyze traffic with respect to the EBrake Website by keeping track of the IP addresses of our visitors. An IP address is a unique number assigned to your computer when you are using your browser on the Internet. We log this information so that we can monitor the number of visitors visiting the EBrake Website; however, we do not link your IP address to any personal identifying information.
Except as described in this Privacy Policy, we will not disclose, share or sell your Personal Information that we collect through the EBrake Services to Third Parties without your express consent. In the event that we want to share your Personal Information with a Third Party, a notice (“Notice”) will be sent to you through the EBrake App requesting permission to disclose your Personal Information to a named Third Party. You will be required to check the relevant box indicating that you consent to the disclosure of your Personal Information to the named Third Party. Notice will be sent to you through the EBrake App for each Third Party who seeks access to your Personal Information that you have provided through the EBrake App.
We will not seek your express consent to disclose, share or sell any Aggregate Information collected through the EBrake Services. As previously mentioned, Aggregate Information does not identify you directly.
We may disclose, share or sell Personal Information about you with other people in the following ways:
a) Aggregate Information. We may disclose, share or sell aggregated, anonymous information that includes or is based on information about you with Third Parties (as defined below). This is information that is combined with the information of other users and does not directly identify you (“Aggregate Information”). We may not limit the Third Parties’ use of the Aggregate Information. Aggregate Information may also be used for our own internal analysis and operations to improve the performance, functionality and content of the EBrake Services.
b) Third Parties. Subject to the consent provisions in Section 2 herein, we may disclose, share or sell Personal Information to one or more third parties (“Third Parties”), including but not limited to, sponsors of the EBrake App and government agencies who may be interested in the Distracted Driving Data collected through the EBrake App. Third Parties may also include business and advertising partners who may use the Personal Information to create targeted marketing campaigns, promotions and contests. We do not control how these Third Parties use or disclose your Personal Information.
c) Our Service Providers, Sub-Processors/Onward Transfer. We may provide your Personal Information to companies that provide services to help us with our business activities, including but not limited to statistical analysis of data collected through the EBrake Services, data hosting providers or customer service. These companies are authorized to use your Personal Information only as necessary to provide these services to us, and in a manner consistent with this Policy.
d) Internal Analysis and Operations. We may disclose Personal Information for our own internal statistical analysis of data collected through the EBrake Services.
e) Social Media Outlets. Personal Information collected through the EBrake Services can be shared at your own discretion through social media outlets such as Facebook and Twitter (collectively, “Social Media Outlets”). Please note that any Personal Information collected through the EBrake Services that you decide to share on any Social Media Outlets will be governed by the terms of use and privacy policies of those Social Media Outlets.
f) Legal Process, Investigations and Emergencies. We may make disclosures or investigations involving your Personal Information if we have a reasonable belief that a disclosure to a third party or an investigation:
i. is necessary for us to comply with legal process or instructions or orders from law enforcement, for example through our receipt of a search warrant, subpoena, judicial proceeding or other legal process;
ii. is made to protect the reputation, rights or property of EBrake and its affiliates in the EBrake Services, users of the EBrake Services, or members of the general public;
iii. s necessary to prevent or identify possible fraud or other wrongdoings involving the EBrake Services or to protect your safety or the safety of others;
iv. is necessary to protect EBrake against misuse or unauthorized use of the EBrake Services;
v. is necessary during an emergency, such as when we believe someone’s physical safety is at risk; and
vi. is necessary to any third party with your prior consent to do so.
The EBrake Services may contain links to Third Party sites that are not governed by this Privacy Policy. When you click on any one of those links, you are contacting another website or Internet resource. We have no responsibility or liability for, control over, those other websites or Internet resources or their collection, use and disclosure of your personal information. Therefore, we recommend that you examine the privacy statements of those sites to learn how your information may be collected, used, shared and disclosed.
We, and Third Parties, including our partners, affiliates, tracking utility company, and services providers, may use cookies. Cookies are pieces of information or data sent to your browser from a web server and stored on your computer’s hard drive for record-keeping purposes. Cookies tell our computer that you have visited before and help to make your visit more personal so you do not have to re-enter info on a return visit. Cookies also allow us to count the number of unique and return visitors who use the EBrake Website. We do not tie the information gathered to your Personal Information.
We, and Third Parties, including our partners, affiliates, tracking utility company, and services providers, may also use web beacons/pixel tags, log files, local shared objects (which may, on the web-coded portions of the Services, include "flash cookies") barcodes, session ID, persistent cookies, and other technologies to collect certain information about users of the EBrake Services, interactions with our applications, websites, emails and online advertisements. For example, through these means, we may collect your browser, device type and its operating system, viewed webpages, links that are clicked, IP address, sites visited before coming to our website, emails we send that you open, forward, or click through to our website. Collecting this information, and linking it with your Personal Information, helps us to best tailor the EBrake Services and enhance your experience by saving your preferences while you are using the EBrake Services, and to help identify site features that may be of particular interest to you. The use of cookies by Third Parties including our partners, affiliates, tracking utility company, services providers is not covered by our Policy.
If you prefer, you can reset your browser to notify you when you have received a cookie or, alternatively, disable cookies and similar technologies through settings on your device or internet browser. Note that the opt-out will apply only to the device or browser that you are using when you elect to opt out. Furthermore, it is important to note that you may not be able to use certain features of the EBrake Services if you choose not to accept cookies.
Children under the age of 18 should always get permission from their parents before sending information about themselves over the Internet. We will not knowingly encourage any child under the age of 18 to register for the EBrake Services or to access those features which require registration. If a child provides us with Personal Information, we ask that any concerned parent or guardian of that child contact us.
Personal Information will be retained as long as necessary for the fulfillment of the purpose for which it was collected and for a reasonable time thereafter or for so long as we are required to maintain such information by law or other applicable rules of regulations.
We will destroy Personal Information collected and stored through the EBrake Services when it is no longer needed or required to be kept, or we remove personal identifier to render it anonymous.
We will take reasonable security measures to store and maintain Personal Information to protect it from loss, misuse, alteration destruction by any unauthorized party while it is under our control. However, you are in control of the information you enter, transmit or display in connection with your use of the EBrake App and you are solely responsible for the consequences of any such actions. While we make reasonable efforts to protect Personal Information, no transmission of data over the Internet is 100% secure. Therefore, we cannot guarantee its absolute security.
The Personal Information that you provide to us may be transferred outside of Canada for processing and storage. We, or our service providers may store Personal Information on servers located in other jurisdictions, including the United States. Please note that privacy laws in such jurisdictions differ from Canadian privacy laws and that in some jurisdictions your Personal Information may be accessed by law enforcement authorities or the courts.
Any of your questions, complaints or claims with respect to the EBrake App should be directed to:
EBrake Technologies Inc.
2969 132nd Street
Surrey, British Columbia, Canada
We may change or update portions of this Privacy Policy at any time by posting a new version of this Privacy Policy on the EBrake Website located at www.ebrake.ca/ privacy. Please check back from time to time so you are aware of any changes or updates to this Privacy Policy. The effective date of this Privacy Policy will be posted at the top of the page. If you continue to access or use the EBrake Services after the changes are in effect, you agree to be bound by the revised Privacy Policy.
