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Privacy Policy

1. INTRODUCTION

Trans + Plus Systems Corp. (“TransPlus”, “we”, “us”, or “our”) is committed to protecting your privacy and the confidentiality of your Personal Information (as defined in Section 2). This privacy policy (“Privacy Policy”) applies to the information we collect, or that you provide, through any of TransPlus’ services, including but not limited to our website https://www.transplus.io/ (“Website”), transportation management software platforms (“Services”), mobile application (“App”), and other online or downloadable tools (collectively, “Online Resources”), in addition to the information we collect offline or through any other means in relation to our services. This Privacy Policy does not apply to the collection of employee information or the information of employee candidates.

This Privacy Policy describes:

• how we collect, use, disclose, and protect the Personal Information (as defined in Section 2) of users of the Online Resources;

• the types of information we may collect from you or that you may provide, including without limitation, when you visit or use the Online Resources; and

• our practices for collecting, using, maintaining, protecting and disclosing that information.

By using the Online Resources and/or otherwise providing us with your Personal Information, you are agreeing to the terms of this Privacy Policy, as it may be amended by us from time to time, and to our collection and use of your Personal Information in accordance with this Privacy Policy.

If you do not agree to this Privacy Policy or to the collection, use and disclosure of your Personal Information in accordance with this Privacy Policy, you may wish to reconsider using the Online Resources or providing TransPlus with your Personal Information.

The Online Resources may include links to third-party websites, plug-ins, services, social media platforms, and other applications. Clicking on those links or enabling those connections may allow the third-party to collect or share data about you. Other websites and plug-ins are governed by privacy policies and practices that may differ significantly from those of TransPlus. We strongly recommend that you review the privacy policies and practices applicable to Personal Information collected on a linked website before submitting any Personal Information to linked websites. We do not accept any responsibility or liability for the content or the privacy practices of other websites, whether or not linked to the Online Resources.

2. PERSONAL INFORMATION

In this Privacy Policy, “Personal Information" means any factual or subjective information, recorded or not, about an identifiable individual. Personal Information can be recorded in any format, and includes, but is not limited to: an individual’s name, date of birth, age, address, city, province, country, and postal code. Personal Information does not include information from which an individual cannot be identified, either alone or in combination with other information.

3. WHAT WE COLLECT

We take steps to ensure that the Personal Information that we collect about you is necessary to achieve the purposes outlined in Section 5. The Personal Information and other information that TransPlus collects may vary depending on how you interact with us and/or the Online Resources. The information we may collect includes, but is not limited to:

• your name (i.e., first name, last name, initials);

• your username;

• your contact information (email address, telephone number, fax number, address);

• your date of birth;

• your gender;

• your Social Insurance Number;

• your company name/employer;

• your government issued identification numbers (e.g., driver’s license number, FAST card number, CDRP card number, TWIC card number, ACE ID number);

• your nationality;

• your travel and citizenship documents (e.g., passport, Enhanced Drivers Licence, birth certificate number, SENTRI card number, NEXUS card number, Visa, permanent resident card);

• the internet protocol (IP) address used to connect your computer to the Internet;

• computer and connection information (e.g., browser type, version and time zone setting, browser plug-in types and versions, operating system, and platform); and

• any other information which is necessary or required for TransPlus to collect as part of its statutory or regulatory compliance requirements.

4. HOW WE COLLECT

TransPlus collects Personal Information in the following ways:

• When you give us information by filling in forms or data fields on the Online Resources, or by corresponding with us by phone, email or otherwise. This includes information you provide when you complete a contact form, register on the Website or App, or subscribe to TransPlus communications.

• When you visit the Website or otherwise use the Online Resources, we may collect information from the computer or electronic device you are using. This may include the use of cookies, web beacons/pixel tags, log files, and other technologies to collect certain information about visitors to the Online Resources, and recipients of our newsletters, invitations and other communications. A cookie is a small file which is placed on your computer or mobile device’s hard drive. Cookies are widely used, and most web browsers are configured to accept cookies automatically. We may use cookies to improve the Website’s functionality, to tailor or improve the content that we may send or show you, and to understand (for analytical purposes) how visitors interact with the Online Resources, messages, and information we provide. We also use cookies and other technologies to identify which portions of the Services are being used and how they are being used. If you prefer not to accept cookies, most Internet browsers will allow you to adjust your cookie settings to prevent your browser from accepting new cookies, to notify you when you receive a new cookie, or to disable cookies altogether. However, please note that disabling cookies may negatively affect the functionality of the Online Resources when you visit.

• Through other, public sources, including trade and business registers or directories, trade fairs, exhibitions, and news or internet sources.

5. USE OF PERSONAL INFORMATION

Our use of your Personal Information is limited to the purposes described in this Privacy Policy, unless we expressly inform you otherwise, we obtain your consent for further uses, or such uses of your Personal Information are required or permitted by applicable law. We do not otherwise sell, license, trade, or disclose any of the Personal Information we have obtained from you.

We use the Personal Information you give to us to:

• carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, goods, and services you request from us;

• enable you to personalize your experience with the Online Resources;

• provide you with information about other goods or services we offer that are similar to those that you have already used or inquired about;

• provide you with information about goods or services we believe may interest you;

• notify you about changes to our products or services, or changes to regulatory requirements that may affect our products or services or your use of them;

• ensure that the content from the Online Resources is presented in the most effective manner for you and for your computer or device;

• carry out any other purpose which is disclosed to you, and to which you consent; and

• ensure regulatory compliance or any other purpose which is permitted or required by applicable law.

We use the Personal Information we collect from your computer or electronic device to:

• improve the Online Resources and ensure that content is presented in the most effective manner for you and your computer or device;

• measure or understand the effectiveness of advertising we deliver to you and others, and to deliver relevant advertising to you; and

• make suggestions and recommendations to you about goods or services that may interest you or them.

We use the Personal Information we receive from other sources to:

• measure or understand the effectiveness of advertising we deliver to you and others, and to deliver relevant advertising to you; and

• make suggestions and recommendations to you and other users of the Online Resources about goods or services that may interest you or them.

6. DISCLOSURE OF PERSONAL INFORMATION

TransPlus may disclose Personal Information to third-party providers of TransPlus, including third parties (such as Crimson Logic or BorderConnect) engaged to assist us in providing the Online Resources (including, but not limited to, hosting, data processing, transaction processing, document management and office administration services) to you or to carry out one or more of the purposes described in this Section. These third-party providers are prohibited from using your Personal Information for any purpose other than the purposes listed in this Section and for the purpose of assisting TransPlus in carrying out its contractual obligations. All third-party providers of TransPlus are required to protect Personal Information disclosed to them by TransPlus and to comply with applicable privacy laws.

We may also disclose your Personal Information:

• to comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law;

• to enforce or apply our Website terms of use, available at https://www.transplus.io/terms-of-use (the “Terms of Use”), and other agreements; and

• if we believe disclosure is necessary or appropriate to protect the rights or property of TransPlus or others.

The information that we collect from you may be processed, stored and/or transferred in or to a destination outside of the jurisdiction in which you reside. Where Personal Information is processed, stored and/or transferred outside of your jurisdiction of residence, it is subject to the laws of that foreign jurisdiction, and may be accessible to that jurisdiction’s government, courts, law enforcement, or regulatory agencies. By submitting your Personal Information or engaging with the Online Resources, you consent to this transfer, storage and/or processing.

However, our practices regarding your information will at all times continue to be governed by this Privacy Policy. Where applicable, we comply with legal requirements to ensure your information is adequately protected when transferred to other jurisdictions.

7. STORAGE AND SECURITY

All Personal Information collected by TransPlus is stored on individual customer data centers or its hosted servers in Montreal, Quebec, as the case may be.

The security of your Personal Information is very important to us. We take reasonable steps to protect your Personal Information, including the use of physical, technical, and administrative measures designed to secure your Personal Information from loss, unauthorized access, use, disclosure, and/or any other breach.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information. Any transmission of Personal Information is at your own risk.

8. ACCURACY AND RETENTION

Except as otherwise permitted or required by applicable law or regulation, we will only retain your Personal Information for as long as it is necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, contractual, accounting, or reporting requirements. Once those purposes are met, your Personal Information will be deleted from our servers.

It is important to ensure that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes.

9. DATA SUBJECT RIGHTS

By law, you have the right to request access to, and correction of, the Personal Information that we hold about you.

If you want to review, verify, correct or withdraw consent to the use of your Personal Information, you may send us an email (using the email address set out in Section 11) to request access to, correct, or delete any Personal Information that you have provided to us. We may not accommodate a request to change Personal Information if we believe the change would violate any law or legal requirement, or if the change would cause the Personal Information to be incorrect. We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the Personal Information that we hold about you, or to make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the Personal Information that we hold about you.

You have the right to revoke your consent to the collection, use, and disclosure of your Personal Information at any time. To withdraw your consent, contact us using the contact information set out in Section 11. Please note that if you withdraw your consent, we may not be able to provide you with certain information and/or services. We will explain the impact to you when you contact us to revoke your consent to help you with your decision.

10. CHANGES

We reserve the right to amend this Privacy Policy at any time by posting an amended Privacy Policy on the Website. You are advised to review the Website regularly for any changes. Any and all such amendments to this Privacy Policy are effective immediately, and your continued access to and use of the Online Resources constitutes your acceptance of this Privacy Policy, as amended.

11. CONTACTING US

If you would like to relay any feedback or have any questions, concerns, or complaints about TransPlus, the Online Resources, and/or this Privacy Policy, please direct them to:

Privacy Officer
Trans + Plus Systems Corp.
200-305 King Street West
Kitchener, Ontario, N2G 0A7
Email: privacy@transplus.io

TransPlus will investigate all complaints and if a complaint is justified, take all reasonable steps to resolve the issue. You also have a right to lodge a complaint with a competent privacy regulator in the region where you normally reside, where we are based, or where an alleged infringement has taken place, such as the Office of the Privacy Commissioner of Canada, the Office of the Information and Privacy Commissioner of Ontario, and/or the Commission d’accès à l’information du Québec.