Privacy Policy

About Your Privacy and This Privacy Policy

This document referred to as the “Privacy Policy” contains details on issues related to your privacy when using our services. This Privacy Policy applies to visitors with respect to the applications, vehicles and websites owned and/or operated by or on behalf of Young Drivers of Canada (“YD” or the “Company”) collectively referred to as the “Platform”. It is intended to inform you of our policies, procedures and practices regarding the collection, use and disclosure of any information that you provide through the Platform.

California residents should read the information available in the Privacy Notice for California Residents below.

European Union residents should read the information available in the Privacy Notice for European Union Residents below about the categories of personal information to be collected from them and the purposes for which the personal information will be used below.

The Privacy Policy is part of our Terms and Conditions. The terms in the Privacy Policy (such as, but not limited to, “we”, “our”, “us”, “Platform” and “Services”) have the same meaning as in our Terms and Conditions document. When you use our Platform you accept and agree to both the Terms and Conditions and to the Privacy Policy. If you do not agree to be bound to the Privacy Policy you should stop using the Platform immediately or cease to provide the Services, as applicable. By accessing and using our Platform or the Services, as applicable, you affirm that you have read the Terms and Conditions and the Privacy Policy and that you understand, agree to and acknowledge all the terms contained in both of them.

Information Collection, Use and Disclosure

Obtaining Consent from Customers

We will obtain the appropriate consent from individuals for the collection, use, or disclosure of their personal information, except where the law provides an exemption. We may obtain express consent for the collection, use, or disclosure of personal information or we may determine that consent has been implied by the circumstances. Express consent is a specific authorization given by the individual to YD, either orally in writing. Implied consent is one in which YD has not received a specific authorization but the circumstances allow us to collect, use or disclose personal information.

Express written consent includes a when you:

Sign a consent form (such as Personal Information Consent)
Provide a letter, application form or other document authorizing certain activities
Provide an authorization electronically (through a computer).

Express oral consent can be given in person or over the telephone. If we obtain express oral consent, we will normally make note of that consent in your file. We will often seek express consent at the onset of a new business relationship. However, we may determine that by an individual seeking service or products through the YD organization, consent has been implied for us to collect, use and disclose personal information in a reasonable manner.

Subject to legal exceptions, consent may be withdrawn at any time. We generally require such withdrawal to be in writing. There may be serious consequences for failing to provide or withdrawing consent, such as YD's inability to provide or renew a contract for service or delivery of a product and/or in the cancellation of an understanding. Depending on whether a new purpose is identified during the course of dealing with personal information, we may choose to seek a new consent. We do not consider a regular updating of information to be a new purpose and, therefore, we will not seek a new consent for this purpose.

Exceptions - There are circumstances in which we are not required to obtain an individual's consent or explain purposes for the collection, use, or disclosure of their personal information. These include but are not limited to:

Collection - We may collect personal information without consent where it is in the individual's interest and timely consent is unavailable, or to investigate a breach of an agreement (such as fraud) or a contravention of the law.
Use - We may use personal information without consent for similar reasons as those listed beside "Collection" above, and also in an emergency situation in which an individual's life, health, or security is threatened.
Disclosure - We may disclose personal information without consent for law enforcement and national security purposes, for debt collection, to a lawyer representing our organization, and in an emergency situation in which an individual's life, health, or security is threatened.

Categories of Information Collected

To let us operate the Platform effectively and to let you use the Platform, including the Services, we may collect, use, and store the information described below. We also disclose certain information to third parties, as described further below. The information we collect is received directly or indirectly from you and generated in the course of your use of the Platform. The data we collect is not used for marketing or any other purposes except as specified in this Privacy Policy.

1) Visitor Data: We collect, use, and store data regarding user visits to its Platform, including the particular pages visited or viewed by the user, the amount of time the user spent on the Platform, Platform errors experienced by the user, and information about the browser or device used to access the Platform, such as the user’s mobile device ID and IP address.

2) Onboarding Data: In addition to the questionnaire responses provided by users in the process of initial registration, we collect, use, and store certain additional data from users during the onboarding process (“Onboarding Data”). This data includes the pages viewed by the user, whether the user clicks the link to begin completing the questionnaire, and whether the user responds to any of the questionnaire prompts.

3) Account Registration Data: We collect, use, and store certain information in connection with the account registration process, such as whether users registered using their Facebook or Google profiles, and whether a user verifies their reported email address or phone number (“Account Registration Data”). We also assign each user who creates an account an anonymized, randomly-generated client ID.

4) Transaction Data: We collect, use, and store certain information regarding payment for services by users and related transactions on the Platform, such as whether a user completed payment for services, signed up for services using an offer, cancelled or otherwise ended a transaction (“Transaction Data”).

5) Login Data: We collect, use, and store data regarding logins to the Platform by registered users and activity conducted during that log in such as when a user logs in, the number of messages received or sent through the Platform during that login, the content of any messages sent or received by users.

6) Customer Data: We collect, use, and store certain data from users that have signed up for YD’s services such as a user’s self-reported name or nickname, age, email address and phone number, service description and service licensing (“Customer Data”).

7) Communications Data: We collect, use, and store communications between users and our customer service team, as well as when you call or email YD (“Communications Data”).

8) Licensing Data: : We collect driver licensing information which helps us to comply with jurisdictional laws such as driver's licence number, classification, restrictions, issue date, and expiry date.

9) Preferences: We collect information that enables us to deliver more effective driver training to you such as preferred learning style, cognitive assessment, occupation, and availability for training.

10) Training Information: We collect information such as where, when, how long, personal performance ratings, driving evaluations, instructor comments, instructor's name, and in which vehicle your driver training took place.

11) Surveys & Reviews: We collect information you provide us with about you and your purchase or service experience through our customer surveys and our Platform.

12) Vehicle Information: We collect information on any collision involving a driver training vehicle including day, date, time, incident report, parties involved, injuries, and lesson number.

13) Surveillance Information: We may collect information through audio, photo and/or video surveillance technology, which is used to enhance the protection and safety of YD’s employees, its customers and invitees by reducing, deterring and assisting in the investigation of incidents of instructional and criminal activity, and protecting property and assets. This policy applies to all YD employees, agents, independent contractors, customers and invitees; and all YD owned or leased land, buildings and vehicles (the “Premises”). It is the policy of YD to ensure: audio, photo and/or video surveillance of the Premises is conducted in a professional, ethical and legal manner; and that video surveillance is used to promote the following goals:
• Your safety
• Safety of the public
• Combatting unauthorized access
• Coordinating operational activities
• Supporting criminal investigations
• Deterring theft and break and enter
• Reinforcing employee safety
• Ensuring adequate staffing for a high level of customer service

Protecting this information is important for us. Other than in the ways detailed in this Privacy Policy, we will never use or disclose any information unless you requested or approved us to do so.

How We Collect Customer Information:

Directly From You: We obtain information directly from you such as when you complete our customer surveys, participate in a contest, focus group, or other promotion, campaign, or event. We may also obtain information directly from you through our Platform.

From Our Franchisees: When you take a Young Drivers of Canada training program, the YD franchisee provides us with the following information about you and/or your son or daughter to enable us to issue you a certificate of completion: your name; address; telephone number; e-mail; birth date; driver's licence number; classroom training test marks; in-vehicle evaluation scores; date of completion; and the course number. The YD franchisee may also provide us with information regarding your experience including your name, contact information, training history, instructor comments, and staff comments.:

From Other Parties: We may purchase or acquire a list of names and addresses, which may include your name and address where you have given your consent, from list vendors to send promotions or product information to the names on the list. We also have relationships with third parties with whom we conduct joint marketing activities such as contests through which we may obtain your name and address and other information about you with your consent. These activities clearly identify the other parties involved and provide information about their privacy practices. Any such other parties are bound by their privacy policy, not ours.

How We Collect Information on Our Platform: When you visit our Platform, we do not collect any personally identifiable information about you unless you provide it to us. All the information on our Platform is available for you to review without providing us with any personal information. If you do not agree with our privacy policy, please do not provide us with any personal information through our Platform. Through our Platform, we collect non-personally identifiable information. This means that we do not track this information on an individual basis that identifies you but rather collect this information on an aggregate basis that includes all site visitors. Your visit automatically generates session log data consisting of the Internet Protocol (IP) address from which you came (which contains no personal information), the website that referred you, the pages you visited, the date and time of those visits and, the amount of time spent on our Platform. We use this information to perform analytics on users' experience while using the site and to improve the functionality of our Platform to better meet user wants and needs, identify popular features, and measure site activity including peak site usage times, page visits, and click-throughs. At times we may conduct voluntary online surveys to obtain your feedback. We request an email address as a means of contacting you. Any personal information collected is used as set out in this Privacy Policy.

Electronic Mail Sent to Us That Contains Personal Information: You may decide to send to us personally identifying information in an email. (For example in a message about your YD experience.) We will only use this personal information to identify you as a customer and to determine how to respond to your email and try to resolve the matter identified in the email.

Purposes for Which Information is Used

We may use the information we collect for one or more of the following purposes:

Communication with you

To contact you or provide you with information, alerts and suggestions that are related to the Platform.
To verify your identity.
To complete an activity you requested, such as register for the Platform or obtain more information.
To reach out to you, either ourselves or using the appropriate authorities, if we have a good reason to believe that you or any other person may be in danger or may be either the cause or the victim of a criminal act.

Delivery of services to you

To create your account on our Platform and let you log in to your account and use the Platform.
To manage your account, provide you with customer support, and ensure you are receiving quality service.
For billing and transaction processing purposes.
To facilitate delivery of the Services.
To provide, support, personalize, and develop our Platform and the Services.
To establish, maintain, and improve our customer relationship with you and to provide you with offers, incentives, marketing programs, or promotional material about us and our products and services, such as coupons and brochures,
To more effectively market our driver training products and services by better understanding your needs and preferences.
To provide you with the services you request and to respond to your comments, concerns, or requests for information through our Platform.
To provide government agency updates where information regarding your driver's license and course records (attendance, marks, etc.) is provided to the appropriate government agencies for certification and road test purposes - Government agencies include the Ontario Ministry of Transportation (MTO), Access Nova Scotia (ANS), Service New Brunswick (SNB), Department of Motor Vehicles for Newfoundland, the Insurance Corporation of British Columbia (ICBC), and the Insurance Bureau of Canada (IBC).
To assist our franchisees in meeting your driver training product and service needs.
To provide you with offers and information about related products offered by others which we think may be of interest to you.
To meet our legal obligations, assist in law enforcement purposes, and protect the business interests of Young Drivers of Canada and our customers.

Administration and improvement of services

To supervise, administer and monitor the Platform.
To improve the safety and security of the Platform and Premises, including YD's dealings with you.
To measure and improve the quality, effectiveness and delivery of our services.
To improve the driver training products and services we offer through customer surveys conducted by us and participation in market research studies conducted by third parties.
To improve our driver training products through research conducted by us, with insurance companies and with credited organizations such as Traffic Injury Research Foundation (TIRF).

Customization and marketing

To advertise and market the Platform and Services to potential users.
To personalize the Platform experience and to deliver content and product and service offerings relevant to individual interests, including targeted offers and ads through our Platform, third-party sites, and via email or text message.

Compliance with laws

To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
To comply with applicable state and federal laws, including, but not limited to laws related to protecting client and public health and safety.

Other uses with consent

Any other purpose with your consent.

Purposes for Which Information is Disclosed to Third Parties

Information about you may be disclosed to third parties for one or more of the following purposes:

1) For business purposes and advertising: We may share a user’s information only as necessary for facilitating the Services. We may also share your information with vendors and service providers, including our data hosting and data storage partners, analytics and advertising providers, and vendors providing technology services and support, payment processing, and data security. We also may share information with professional advisers, such as auditors, law firms, and accounting firms.

2) With your direction or consent: We may share your information with third parties if you request or direct us to do so.

3) With affiliates within our corporate group: We may share your information with any subsidiaries or parent companies within our corporate group.

4) Compliance with law: We may share your information with a court, a regulatory entity, law enforcement personnel, or pursuant to a subpoena, to comply with applicable law or any obligations thereunder.

5) In the context of a transaction: We may share your information in connection with an asset sale, merger, bankruptcy, or other business transaction.

6) For other business reasons: We may share your information to enforce any applicable terms and conditions and Terms of Use, and to ensure the safety and security of the Platform and our users.

Note that if you make any information publicly available on the Platform, anyone may see and use such information.

Your rights

You have a number of rights with regard to your personal data:

You have the right to be given information about how your data is processed and why.
You have a right to access the personal data we hold about you.
You have the right to ensure the information we hold about you is accurate and complete.
You have the right to have your personal data deleted.
You have the right to ask us to restrict processing your personal data.
You have the right to ask us to transfer your personal data.
You have the right to object to us processing your data.
You have the right to withdraw consent to us sending you information by email.
You have rights in relation to automated decision making and profiling.

Platform User Account

You can use your Platform user account to opt in and out of receiving email communications and to update your personal information. If you would like to delete your Platform account, please contact us by email at info@yd.com. Your account is automatically deleted after seven years of inactivity.

Purchases through the Platform

We will need your payment card details and billing address if you make any purchases, in order to take payment and perform refunds if necessary. We do not keep your card number. Order confirmations will be sent by email.

Subscriptions and Newsletters

We will use your name and email address to provide you with emails and newsletters you have chosen to receive. You will be able to unsubscribe from these at any time by clicking on the link in the email or contacting us at info@yd.com.

Opting out of Marketing Communication

You can opt out of receiving email marketing by unsubscribing using the unsubscribe link provided in all of our marketing email communications.

Cookies and Web Beacons

Like many applications, we use “cookies” and “web beacons” (also known as pixels) to collect information. A “cookie” is a small data file that is transferred to your computer’s hard disk for record-keeping purposes. We collect cookies that are necessary for the Platform to function, cookies that enhance the Platform’s performance, and cookies used for third-party tracking. A “web beacon” is a tiny and sometimes invisible image or embedded code, placed on a web page or email that can report your visit or use to a third party. Web beacons are typically used by third parties to monitor the activity of users for the purpose of analytics, advertising optimization, or page tagging. Additional information regarding web beacons is available on Wikipedia.

You can change your browser’s settings so it will stop accepting cookies or to prompt you before accepting a cookie. Opt-out options for cookies should be located at the account holder section of the Platform.

Use of Cookies, Web Beacons, and Similar Technology for Analytics

We may use third party cookies for the purposes of web analytics, attribution, and error management. Our Platform may use vendor services that use cookies, web beacons, and similar technology to collect and store anonymous information about you, including when you pay for services, load a page, indicate that you heard about us on social media, sign up for services, enter your payment information (but the payment details are not disclosed), start the intake questionnaire, and your response as to the referral source to the Platform.

Our Platform also uses analytics vendors to collect information (for example, Visitor Data and Onboarding Data) about user actions on our Platform for purposes of analytics and analysis of certain Platform usage.

Use of Cookies, Web Beacons, and Similar Technology for Advertising Networks

You and others may see certain ads for our services or for the Platform on other websites because we may participate in ad networks. Ad networks allow us to target our messaging to users through demographic, interest-based, and contextual means. These networks track an individual’s online activities over time by collecting information through automated means, including through the use of cookies, web server logs, and web beacons. The networks use this information to show advertisements that may be tailored to an individual’s interests. The information our ad networks may collect includes information about your visits to websites that participate in the relevant ad networks, such as the pages or advertisements you view and the actions you take on the websites. This data collection may take place both on our Platform and on third-party websites that participate in the ad networks. This process also helps us track the effectiveness of our marketing efforts and assists other websites and advertising partners to find you or people like you on different platforms, including social media websites.

Social and General Information Tools

We may use several publicly-available tools and information exchange resources, such as (but not limited to) a blog, a Facebook page, a Twitter account, Instagram account and others (collectively “Social and General Information Tools”). Any information you provide or share while using Social and General Information Tools may be read, accessed, and collected by that site and users of that site according to their Privacy Policy.

In order to provide the Services, we may ask you for some of the following information. This list is not exhaustive.

• Name, telephone number, and postal address – As applicable, we need these to send you publications and other information relevant to the Services.

• Email address – We need this to provide the Services, such as your online account and email information. We use your email address to communicate with you about your account, benefits, news and services, surveys, and activities.

• Date of birth - This is used for verification and statutory compliance purposes.

You can view and update most personal data held by logging into the account holder section of the Platform. Please email us info@yd.com if you would like to view your data or if you would like us to update it for you.

If you decide to terminate your use of the Platform, we will keep your personal information on our database for up to seven years. This is statutorily mandated and/or to allow you to rejoin the Platform during this period without having to submit your information and/or supporting documentation again.

We will retain some basic information about your Platform access for archiving and historical research or for conducting statistical analysis of our users. Where appropriate this will be anonymized and any personal data held will be kept to a minimum.

Phishing

Online identity theft and account hacking, including the practice currently known as “phishing”, are of great concern. You should always be diligent when you are being asked for your account information and you must always make sure you do that in our secure system. We will never request your login information or your credit card information in any non-secure or unsolicited communication (email, phone or otherwise).

Links

The Platform may contain links to other websites, services or offers which are owned, operated or maintained by third parties. If you click on a third party link, you will be directed to that website or service. The fact that we link to a website or service is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not have control over third party websites and services and we do not have control over their privacy policies and terms of use.

Security of Information

While using any internet-based service carries inherent security risks that cannot be 100% prevented, our systems, infrastructure, encryption technology, operation and processes are designed, built and maintained with your security and privacy in mind. We apply industry standards and best practices to prevent any unauthorized access, use, and disclosure. We comply with all applicable federal, provincial and state laws, and regulations regarding data privacy.

Service Providers

We may employ third party companies and individuals to facilitate our Platform, to perform certain tasks which are related to the Platform, or to provide audit, legal, operational or other services for us. These tasks include, but are not limited to, customer service, technical maintenance, monitoring, email management and communication, database management, billing and payment processing, reporting and analytics. We will share with them only the minimum necessary information to perform their task for us and only after entering into appropriate confidentiality agreements.

Children’s Privacy

We do not knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow such persons to become our user. The Platform is not directed and not intended to be used by children under the age of 13. If you are aware that we have collected Personal Information from a child under age 13 please let us know by contacting us and we will delete that information.

Compliance with Laws and Law Enforcement

We cooperate with governments and law enforcement officials to enforce and comply with the law. We may disclose information necessary or appropriate to protect the safety of the public or any person, to respond to claims and legal process (including but not limited to subpoenas), and to prevent or stop activity that may be illegal or dangerous.

Changes to the Privacy Policy

We may update this privacy statement at our sole discretion. The date of the last revision of this policy appears at the end of this page. We encourage you to periodically review this page for the latest information on our Privacy Policy and practices. Regardless of changes to our Privacy Policy, we will never use the information you submit under our current privacy notice in a new way without first notifying you and giving you the option to stop using the Platform.

Contacting us

If you have any questions or concerns about this Privacy Policy or our privacy-related practices, please email us at info@yd.com

CALIFORNIA – Privacy Notice for California Residents

This Privacy Notice for California Residents supplements and is expressly made part of the information contained in the Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this Notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”). Any terms defined in the CCPA have the same meaning when used in this Notice.

Information We Collect

Through your use of our Platform, we collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”). The description of the information that we collect is provided above, in the section titled “Categories of Information Collected.” The information that we share with third parties is described in greater detail above in the section titled “Purposes for Which Information is Disclosed to Third Parties.”

In particular, our Platform is expected to collect the following categories of personal information from consumers within twelve (12) months. Additionally, we expect to disclose the following categories of information for a business purpose within twelve (12) months:

Category / Collection / Disclosure for a business purpose

A. Identifiers. / Yes / Yes

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). / Yes / Yes

C. Protected classification characteristics under California or federal law. / Yes / Yes

D. Commercial information. / Yes / Yes

E. Biometric information. / No / No

F. Internet or other similar network activity. / Yes / Yes

G. Geolocation data. / Yes / Yes

H. Sensory data. / No / No

I. Professional or employment-related information. / No / No

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). / No / No

K. Inferences drawn from other personal information. / Yes / Yes

The information that we share with third parties is described in greater detail above in the section titled “Purposes for Which Information is Disclosed to Third Parties.”

We obtain the categories of personal information listed above from the following categories of sources:

Directly from you. For example, from information you submit on the Platform during the process of using and/or paying for our Services.
Indirectly from you. For example, from observing your actions on our Platform or on an application provided by us.
From third-party business partners such as social media sites, ad networks, and analytics providers.

Use of Personal Information

We may use the personal information we collect for one or more of the following business or marketing purposes:

Category of Personal Information & Purpose of Use

1. Identifiers. We may use Identifiers (provided account name, email address, online identifier, and IP address) to communicate with you, deliver our services to you, facilitate the Services, customize and market the services (attribution and optimization), conduct research and development and other activities to improve our service, understand how you interact with our services, and comply with the law.

2. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). We use your name (if you provide it to us) and the payment details you provide to us to communicate with you, deliver services to you, and facilitate the Services. We may also use your name and contact details to optimize our marketing to prospective users.

3. Protected classification characteristics under California or federal law. We may use your age, religion, sex, orientation and medical condition to customize and deliver the services to you. If you are a veteran or have military status, we may use this information to offer you a discount for our services. We may also use this information to conduct research and development and other activities to improve our service, show and optimize advertising, and understand how you interact with our services.

4. Commercial information. We use information regarding your purchase of our services to customize and market services, conduct research and development and other activities to improve our services, show and optimize advertising, and understand how you interact with our services.

5. Internet or other similar network activity. We use information regarding your activity on our Platform to deliver our services to you, customize and market services (attribution and optimization), conduct research and development and other activities to improve our service, and understand how you interact with our services.

6. Geolocation data. We use your geolocation information to personalize the services to you and for analytics.

7. Inferences drawn from other personal information. We use information regarding your actions on our Platform and the information you provide to deliver our services to you, customize and market the services, conduct research and development and other activities to improve our service, and understand how you interact with our services.

Disclosure of Personal Information

Within the 12 months of this Privacy Policy, we expect to share personal information with the following categories of third parties:

1. Identifiers.

We may disclose your IP address, unique identifier, or email address to our analytics vendors for analytics and to ad network partners for advertising optimization and attribution.
We may disclose your credit card information to payment processing vendors for payment processing.
If you are a user that uses the Platform as the result of a business arrangement we have with an organization you are affiliated with or with your employer, we may disclose, with your authorization, identifiers to those entities in order to deliver the services to you.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
We may disclose your contact information to webinar providers and to customer support and payment processing vendors to provide services for the Platform and to ad network partners for advertising optimization and attribution.
We may disclose personal information necessary to provide the Services.
We may disclose your credit card information to payment processing vendors for payment processing.

2. Protected classification characteristics under California or federal law.

We may disclose information regarding your age, sex, race, gender, sexual orientation, medical conditions, and disabilities to our advertising partners to optimize marketing, and as necessary to provide the Services.

3. Commercial information.

We may disclose information regarding your purchase of our services to our advertising partners to optimize marketing.
We may disclose your credit card information to payment processing vendors for payment processing.

4. Internet or other similar network activity.

We may disclose information regarding your activity on our Platform to our advertising partners to optimize marketing.

5. Geolocation data.

We may disclose geolocation data to our advertising partners to optimize marketing.

6. Inferences drawn from other personal information.

We may disclose information regarding your activity on our Platform to our advertising partners to optimize marketing.

7. All data categories

We may disclose all necessary information about you to comply with legal requirements that apply to us.
We may disclose information about you at your direction or request.
We may disclose information about you to vendors and other contractors and advisors that provide services to us, including data hosting and storage providers, analytics providers, engineering vendors, data security vendors, marketing services processors, lawyers, advisors, auditors, accountants, and others.
We may disclose information about you in connection with an asset sale, merger, bankruptcy, or other business transaction.
We may disclose information about you with corporate affiliates as necessary for internal business operations, and with subcontractors as necessary in the provision of services to you.

The CCPA defines “sale” broadly. It includes the sharing of personal information in exchange for anything of value. According to this broad definition, in the 12 months before this section was last updated, our use of analytics and targeting cookies and web beacons to deliver advertising tailored to individual interests may have been considered a “sale” of personal information.

Your Rights and Choices

The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Right to Request Access to Information

You have the right to request that the Company disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Your Rights), we will disclose to you:

The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting that personal information.
The categories of third parties with whom we shared that personal information.
The specific pieces of personal information we collected about you.
If we disclosed your personal information for a business purpose and identifying the personal information categories that each category of recipient obtained.

Right to Request Deletion of Information

You have the right to request that we delete any of your personal information that we collected about you and retained, subject to certain exceptions. Once we receive your request and verify who you are, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
We may also deny your request if the information in question is not subject to the CCPA. Examples of such information include de-identified information, information covered by the Health Insurance Portability and Accountability Act, and information covered by the California Confidentiality of Medical Information Act.

Right to opt out of sale

You have the option to opt out of the use or disclosure of your information that is considered a “sale” under the CCPA. If you would like to opt out of the use and disclosure of your information, go to the account holder section of the Platform to manage your preferences.

Exercising Your Rights

To exercise the rights listed above, please submit a request in writing to us via the submission methods listed below. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a request related to your personal information. You may also make a request on behalf of your minor child.

You may only make a request for access twice within a 12-month period. Your request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a request does not require you to create an account with us. We will only use personal information provided in a request to verify your identity or authority to make the request.

You may submit requests by making the request in writing and sending it to:

By Mail: Young Drivers of Canada,951 Rowntree Dairy Road, Suite 101, Vaughan, Ontario Canada L4L 8Z5

By Email: info@yd.com

By Phone: (416) 322-7000

Response Timing and Format

We endeavour to respond to a request within forty-five (45) days of its receipt. If we require more time (up to 90 days from the day of receipt), we will inform you of the reason and extension period in writing.

For Requests to Access, our response will only cover the 12-month period preceding the request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. We will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. We will not:

Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Platform that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to info@yd.com.

Changes to Our Privacy Notice

We reserve the right to amend this Privacy Notice at our discretion and at any time. When we make any changes to this Privacy Notice, we will post the updated Privacy Notice on our Platform and update the Privacy Notice’s effective date. Regardless of changes to our Privacy Policy, we will never use the information you submit under our current privacy notice in a new way without first notifying you and giving you the option to stop using the Platform. Your continued use of our Platform and services following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this Privacy Notice, the ways in which we collect and use your information described above, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

To: Data Protection Officer, Young Drivers of Canada,

By Mail: 951 Rowntree Dairy Road, Suite 101, Vaughan, Ontario Canada L4L 8Z5

By Email: info@yd.com

By Phone: (416) 322-7000

General Data Protection Regulation (GDPR) Notice

This section provides additional information about our Privacy Policy relevant to users from the European Union (EU) and Switzerland. It supplements and should be read in conjunction with the rest of the Privacy Policy. Under the GDPR, YD is the Controller with respect to your Personal Data.

YD may use your personal information:

When it is necessary to do so to perform our obligations in accordance with any contract that we may have with you, for example to manage your account, and to respond to enquiries about your use of the Platform.
When it is in our legitimate interests or a third party’s legitimate interests to use personal information in such a way to ensure that we provide the Platform in the best way that we can. In particular, we have a legitimate interest in using your personal information for product development and internal analytics purposes, and otherwise to improve the safety, security, and performance of the Platform. We only rely on our or a third party’s legitimate interests to process your personal information when these interests are not overridden by your rights and interests.
When it is necessary to do so in order to comply with any legal obligations imposed upon us, for example under applicable law.
When you have consented to the use of your personal information, for example for marketing purposes or to track your online activities via cookies and similar technologies.

Your Rights and Choices:

EU and Swiss residents have specific rights regarding their personal information. This section describes your rights if you are resident in the EU or Switzerland, and explains how to exercise those rights.

Right of access: You may be entitled to ask us for a copy of any personal information which we hold. This right is known as a ‘Subject Access Request.’ We will normally send you a copy of the personal information within one month of your request. However, that period may be extended by two further months where necessary, taking into account the complexity of the request or the difficulty in accessing the personal information that you request. There is usually no charge; but in exceptional circumstances we may charge but will discuss this with you if those circumstances apply.

Right to rectification: If the personal information we hold about you is inaccurate, you may request rectification. The personal information will be checked, and, where appropriate, inaccuracies will be rectified.

Right to erasure: In certain circumstances, you may be entitled to ask us to erase your personal information.

Right to data portability: In certain circumstances, you may wish to move, copy, or transfer the electronic personal Information that we hold about you to another organization.

Right to object: You may object to your personal information being used for direct marketing. You may object to the continued use of your personal information in any circumstances where we rely upon consent as the legal basis for processing it. Where we rely upon legitimate interests as the legal basis for processing your personal information, you may object to us continuing to process your personal information, but you must give us specific reasons for objecting. We will consider the reasons you provide, but if we consider that there are compelling legitimate grounds for us to continue to process your personal information, we may continue to do so. In that event, we will let you know the reasons for our decision.

Rights related to automated decision-making including profiling: We use limited personal information to operate the Platform and to carry out certain profiling activities to support and grow our business. When doing so, we rely upon our legitimate interests as the lawful basis for processing your personal information and you may exercise the above rights if you do not wish us to process your personal information in this way.

To exercise the rights in relation to your Personal Information set out in this section, please contact us by send an email to info@yd.com.

International Data Transfers

The Platform is controlled and operated by us from Canada and the United States of America. By accepting the terms of this Privacy Policy you agree that any personal information you provide to us through use of the Platform may be stored and processed, transferred between and accessed from Canada and the United States of America and other countries that may not guarantee the same level of protection of personal information as the one in which you reside. However, we will handle your personal information in accordance with this Privacy Policy at all times.

You can contact our Data Protection Officer with questions, about this policy, or about your personal information by writing to:

Young Drivers of Canada., Data Protection Officer, c/o Legal Department, 951 Rowntree Dairy Road, Suite 101, Vaughan ON L4L 8Z5 Canada; info@yd.com

Whilst we will always work with you to resolve any concerns you have about the use of your personal information, under GDPR you have the right to lodge a complaint with the supervisory authority in your country of residence if you have any concerns about our use of your personal information.

Last Updated and Effective: March 6, 2024