Privacy Policy

Chill Delivery Services Ltd. (the “Corporation”) recognizes that your right to privacy is an important issue. We understand your interest in maintaining and protecting your private information. As a result, the Corporation manages your personal information as described in this Privacy Policy.

This Privacy Policy provides you with the safeguards set forth in the Canadian federal Personal Information Protection and Electronic Documents Act (PIPEDA) and Alberta’s Personal Information Protection Act (PIPA) (“Privacy Laws”). Nothing in this Privacy Policy will limit the Corporation’s rights and obligations pursuant to such Privacy Laws. the Corporation is also obliged to comply with provincial and federal legislation, including without limitation the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (“Applicable Legislation”). In some cases, Applicable Legislation may impact the Corporation’s Privacy Policy as set out herein.

This Privacy Policy applies to personal information concerning the Corporation’s customers, drivers, business partners and suppliers (“you”) that is collected, used or disclosed by the Corporation. It also applies to the management of personal information in any form whether oral, electronic or written. The Privacy Policy does not apply to information that is protected by other the Corporation policies and practices or through contractual arrangements, unless specifically provided in such contractual arrangements.

YOUR CONSENT

CONSENT

BY SUBMITTING PERSONAL INFORMATION TO THE CORPORATION INCLUDING BY ACCESSING AND USING THIS WEBSITE, OR THE CORPORATION’S AGENTS, SERVICE PROVIDERS AND DRIVERS, YOU AGREE THE CORPORATION AND ITS AGENTS, SERVICE PROVIDERS AND DRIVERS MAY COLLECT, USE AND DISCLOSE SUCH PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY AND AS PERMITTED OR REQUIRED BY PRIVACY LAWS.Subject to legal and contractual requirements, you may refuse or withdraw your consent to certain of the identified purposes at any time by contacting the Corporation’s Privacy Officer. If you refuse or withdraw your consent, we may not be able to provide you or continue to provide you with certain services or information which may be of value to you. If you provide the Corporation or its service providers and agents with personal information of another individual, you represent that you have all necessary authority and/or have obtained all necessary consents from such person to enable us to collect, use and disclose such personal information for the purposes set forth in this Privacy Policy.

WHAT PERSONAL INFORMATION DO WE COLLECT?

Personal information is information about an identifiable individual, as defined in applicable Privacy Laws. Generally speaking, personal information does not include:

a) anonymous or aggregated information that does not allow an individual to be identified;

b) information regarding companies and other “legal persons”;

c) business contact information such as your name, title or position, business address, telephone number or fax number; and

d) payment information such as credit card number, name on the card, expiry date, and security number on the reverse of the card for the purpose of paying for each ride, please note that the payment may be processed by an affiliate of the Corporation or a third party service provider.

The types of personal information that the Corporation may collect from you from time to time include: your name, home address, telephone number, personal email address, your forwarding address (e.g. during a vacation), previous address(es), billing and account information (such as credit card, or bank account number), your mailing preferences, delivery instructions, and customer service preferences. In addition, from time to time, we may ask you to provide us with more detailed information regarding your interests, occupation and background. For example, we sometimes ask our customers to complete surveys in order to get a better sense of who they are and what issues, products or services may be of interest to our clients.

THE PRIVACY PRINCIPALS THE CORPORATION FOLLOWS

the Corporation collects, uses and discloses your personal information by employing “fair information practices” as described in the following ten privacy principles and embodied in the Personal Information Protection and Electronic Documents Act:

1. Accountability: the Corporation is responsible for personal information under its control and as a result has designated an individual as the person who is accountable for the Corporation’s compliance with the ten principles (“Privacy Officer”). As such:

a) accountability for the Corporation’s compliance with the principles rests with the Privacy Officer, even though other individuals within the Corporation may be responsible for the day-to-day collection and processing of personal information. In addition, other individuals within the Corporation may be delegated to act on behalf of the Privacy Officer;

b) the identity of the Privacy Officer designated by the Corporation to oversee the Corporation’s compliance with the principles shall be made known upon request; and

c) the Corporation is responsible for personal information in its possession or custody, including information that has been transferred to a third party for processing. the Corporation shall use contractual or other means to provide a comparable level of protection while the information is being processed by a third party.

2. Identifying Purposes: In general, the Corporation collects, uses and discloses personal information about you in order to provide our customers with business forms development and processing services. More specifically, the Corporation collects, uses and discloses your personal information for the following purposes:

Chill Delivery Services Ltd. Privacy Policy 

a) to establish and maintain commercial relationships with clients, suppliers and other third parties, including to administer accounts, collect and process payments, and to fulfill contractual and legal obligations;

b) to develop and manage our business and operations. This may include the sharing of personal information by and between the Corporation personnel and affiliated companies, and with third party service providers and agents, for such purposes;

c) to detect and protect the Corporation and other third parties against error, fraud, theft and other illegal activity, and to audit compliance with the Corporation’s policies and contractual and legal obligations;

d) to distribute our newsletters and other material to individuals on our mail and email lists, including via third party mailing houses and e-mail service providers;

e) to engage in business transactions, including the purchase, sale, lease, merger, amalgamation or any other type of acquisition, disposal, securitization or financing involving the Corporation;

f) to understand and respond to client, supplier and other third party needs and preferences, including to contact and communicate with such parties and to conduct surveys, research and evaluations;

g) to develop, enhance, market, sell or otherwise provide the Corporation’s products and services;

h) to market, sell or otherwise provide products and services of third parties with whom the Corporation has a commercial relationship;

i) as permitted by, and to comply with, any legal or regulatory requirements or provisions; and

j) for any purpose to which you consent.

the Corporation will collect, use and disclose only that personal information necessary for the purposes that have been identified.

3. Consent: The knowledge and consent of the individual are required for the collection, use, or disclosure of personal information, except as permitted by Privacy Laws. Pursuant to this Privacy Policy, you acknowledge your consent to the Corporation’s collection, use and disclosure of your personal information, or the personal information of another individual which you provide to the Corporation, as stated above. Generally, should a different purpose to the collection, use or disclosure of your personal information be proposed by the Corporation, the Corporation shall seek your consent at the same time it collects the information. However, the Corporation may seek consent to use and disclose personal information after it has been collected, but before it is used or disclosed, for a new purpose. You may withdraw consent at any time to some or all of the purposes indicated below, subject to legal or contractual restrictions and reasonable notice. Please note, however, that in some circumstances, we may not be able to Chill Delivery Services Ltd. Privacy Policy provide you with our services if you withdraw your consent to our use of your personal information.

NOTE: In certain circumstances under Privacy Laws, personal information can be collected, used, or disclosed without the knowledge and consent of the individual. For example, legal, medical, or security reasons may make it impossible or impractical to seek consent. When information is being collected for the detection and prevention of fraud or for law enforcement, seeking the consent of the individual might defeat the purpose of collecting the information.

4. Limiting Collection: The collection of personal information shall be limited to that which is necessary for the purposes identified by the Corporation. Information shall be collected by fair and lawful means and may be collected from other sources including but not limited to credit bureaus or other third parties who represent that they have the right to disclose the information. In most cases, collection shall be pursuant to appropriate contractual arrangements.

5. Limiting Use, Disclosure, and Retention: Personal information shall not be used or disclosed for purposes other than those for which is was collected, except with the consent of the individual or as required or permitted by Privacy Laws or other Applicable Laws. Personal information shall be retained only as long as necessary for the fulfillment of those purposes or as required by law.

the Corporation may collect from and/or disclose your personal information to:

a) a person who, in the reasonable judgment of the Corporation, is providing or seeking the information as your agent;

b) any of the companies and business entities that form part of the Corporation;

c) an organization or individual retained by the Corporation to perform functions on its behalf, such as contractors, consultants, auditors, software developers (including web-site developers and hosts), data processing, document management and office services;

d) an organization or individual retained by the Corporation to evaluate your creditworthiness or to collect debts outstanding on an account;

e) financial institutions and credit card providers, on a confidential basis and solely in connection with user account administration (including deposits and payments), fraud investigations and security, and processing of payments and deposits through the the Corporation services;

f) a financial institution, on a confidential basis and solely in connection with the assignment of a right to receive payment, the provision of security or other financing arrangements;

g) our auditors and professional advisors;

h) another person or corporation as part of conducting business together or pursuant to the sale of all or substantially all of the Corporation’s assets related Chill Delivery Services Ltd. Privacy Policy 5 to one or more specific lines of business, subject to the other person or corporation agreeing to manage personal information in accordance with Privacy Laws;

i) another company or person for the development, enhancement, marketing or provision of any of the Corporation’s products or services;

j) an agent or third party retained by the Corporation in connection with the Corporation ‘s administration or the provision of the Corporation ‘s products or services;

k) credit grantors and reporting agencies;

l) applicable public authorities where such disclosure is required pursuant to Applicable Laws (including without limitation the Financial Transactions and Reports Analysis Centre of Canada); and

m) a public authority or agent of a public authority, if in the reasonable judgment of the Corporation, it appears that there is imminent danger to life or property which could be avoided or minimized by disclosure of this information.

Except as permitted in this principle, the Corporation does not provide or sell its customer lists to any outside company for use in marketing or solicitation.

6. Accuracy: Personal information shall be as accurate, complete, and up-to-date as is possible. the Corporation will update personal information as and when necessary to fulfill the identified purposes or upon notification from you. the Corporation will not routinely update personal information, unless such process is necessary to fulfill the identified purposes. If ever your contact and/or other personal information changes, please feel free to contact us so that we can update our records.

7. Safeguards: Personal information shall be protected by security safeguards appropriate to the sensitivity of the information. The security safeguards are designed to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. The nature of the safeguards will vary depending on the sensitivity of the information that has been collected, the amount, distribution, and format of the information, and the method of storage. The methods of protection include:

a) physical measures, such as locked filing cabinets and restricted access to offices;

b) organizational measures, such as security clearances and limiting access on a “need-to-know” basis; and

c) technological measures, such as the use of passwords, firewalls and encryption.

8. Openness: the Corporation shall make readily available to you information about its Privacy Policy and practices relating to the management of personal information. For example: Chill Delivery Services Ltd. Privacy Policy 6

a) the Corporation shall be open about its Privacy Policy and practices with respect to the management of personal information. This information shall be made available in a form that is generally understandable;

b) the information made available shall include:

i) the name or title, and the address, of the Privacy Officer to whom complaints or inquiries can be forwarded;

ii) the means of gaining access to personal information held by the Corporation;

iii) a description of the type of personal information held by the Corporation, including a general account of its use;

iv) a copy of any brochures or other information that explain the Corporation’s policies, standards, or codes; and

v) what personal information is made available to related organizations, i.e.: affiliated companies; and

c) the Corporation may make information on its Privacy Policy and practices available in a variety of ways. The method chosen depends on the nature of its business and other considerations. For example, the Corporation may choose to make brochures available in its place of business, mail information to its customers, provide online access, or establish a toll-free telephone number.

9. Individual Access: Upon request, subject to certain exceptions under Privacy Laws, you shall be informed of the existence, use, and disclosure of your personal information and shall be given access to that information. You may wish to challenge the accuracy and completeness of the personal information and have it amended as appropriate. NOTE: In certain situations, under Privacy Laws, the Corporation may not be able to provide access to all of your personal information it holds. The reasons for denying access will be provided to you upon request. Exceptions may include information that is prohibitively costly to provide, information that contains references to other individuals, information that cannot be disclosed for legal, security, or commercial proprietary reasons, and information that is subject to solicitor-client or litigation privilege.

10. Challenging Compliance: You may wish to address a concern regarding the Corporation’s compliance with the above principles to the Corporation’s Privacy Officer. the Corporation shall investigate all complaints. If a complaint is found to be justified, the Corporation shall take appropriate measures to resolve the complaint, including, if necessary, amending this Privacy Policy and practices.

PRIVACY AND OUR WEBSITE

Cookies – When you access the Corporation website, we may use a browser feature called a “cookie” to collect information, such as the type of Internet browser and operating system you use, the domain name of the website from which you came, date and duration of the visit, number of visits, average time spent on our website, pages viewed and number of cookies Chill Delivery Services Ltd. Privacy Policy 7 accumulated. A cookie is a small text file containing a unique identification number that identifies your browser, but not necessarily you, to our computers each time our website is visited. Unless you specifically inform us (e.g. by registering for an event or sending us correspondence from the website), we will not know who you are. In addition to the identified purposes described in our Privacy Policy, we may use this website information and share it with other organizations with whom we have a commercial relationship to measure the use of our website, to improve the functionality and content of the website and to facilitate usage by you. You can reset your browser either to notify you when you have received a cookie or refuse to accept cookies. However, if you refuse to accept cookies, you may not be able to use some of the features available on our website.

Online Communications – In order to provide you with services or information, you may voluntarily submit personal information to us through our website for purposes such as conducting business online, asking a question, obtaining information, reviewing or downloading a publication, participating in an event, and participating in contests and surveys. If you are known to the Corporation as a registered user of an online service, we may combine and store personal information about your use of our website and the online information you have provided with certain other online and offline information we may have collected. All collection, use and disclosure of personal information obtained through our website shall be subject to this Privacy Policy and Privacy Laws.

E-mail Communications – Occasionally, we may send marketing or promotional e-mail communications to you with information that may be useful, including information about the services of the Corporation and other third parties with whom we have a relationship. We will include instructions on how to unsubscribe and inform us of preferences if you decide you do not want to receive any future marketing or promotional e-mails from the Corporation.

Links – Our website may contain links to other websites which are provided as a convenience only. Visitors are advised that other third party websites may have different privacy policies and practices than the Corporation, and the Corporation has no responsibility for such third party websites regarding its privacy policies on its content generally.

CHANGES TO THE PRIVACY POLICY

The Corporation reserves the right to modify or supplement this Privacy Policy at any time. If we make a change to this Privacy Policy, we will post the revised Privacy Policy on our websites. We will provide to you such revised Privacy Policy upon request to the Privacy Officer. However, the Corporation will obtain the necessary consents required under applicable Privacy Laws if it seeks to collect, use or disclose an individual’s personal information for purposes other than those to which your consent has previously been obtained unless otherwise required or permitted by Privacy Laws.

FURTHER INFORMATION

The Corporation has appointed a Privacy Officer to oversee compliance with this Privacy Policy and applicable Privacy Laws. For information on the Corporation’s privacy practices, please contact our Privacy Officer at:

Address: #3, 424 11 Ave N.E Calgary, AB. T2E 0Z3, Attention: Privacy Officer

Email: privacyofficer@chilll.ca