INTRODUCTION & SCOPE
Green Coast Ventures Inc. dba Whistle, WhistleRide and Whistle Ride Co. (“Whistle!”, “we”, “our”, or “us”) is a licensed transportation network services provider. We provide access to a technology platform that enables individuals to use our mobile ride hailing applications Whistle!Ride and Whistle!Drive (the “App”) to connect riders with certified drivers.
WhistleRide allows individuals to request, receive and pay for transportation services from drivers. WhistleDrive allows individuals to apply for and if approved by Whistle!, provide, transportation services to individuals within designated geographical areas in British Columbia.
The purpose of this Privacy Policy (the “Policy”) is to provide you with information about how we collect, use, disclose and protect your personal informal information in connection with the transportation network services and functions of Whistle! through your use of the Whistle! website, https://whistle.ca (the “Site”), the App, and other services made available through the Site and the App (the “Services”). This Policy applies to all users of the Site, App and Services (“Users”), including but not limited to, riders and drivers (including prospective riders and drivers). We are committed to protecting your privacy and will manage your personal information in accordance the B.C. Personal Information Protection Act and other applicable provincial or federal legislation.
By installing the App, creating a Whistle! account, or using the Site, App or Services, you acknowledge the notices in this Policy and you consent to our collection, use, disclosure, and retention of your personal information in accordance with this Policy and as otherwise permitted by law. As a transportation network services provider licenced by the BC Transportation Board (the “Board”), we are required to collect and disclose certain information as described on the Board’s publicly available website. You may withdraw your consent at any time by giving Whistle! reasonable notice, but consent may not be withdrawn where doing so would frustrate performance of a legal obligation.
COLLECTION OF PERSONAL INFORMATION
Whistle! collects personal information from Users when they interact with us or use the Site, the App and/or the Services. Whistle! also collects some personal information from Users automatically, which is addressed in more detail below.
In some cases, Whistle! may seek your consent for the use and disclosure of your personal information after it has been collected, but before it has been used or disclosed (e.g. where we want to use your personal information for a purpose not previously identified to you). We will not use or disclose your personal information for any new purpose without first identifying the new purpose and providing notice to you or obtaining your consent (as applicable), unless otherwise permitted by law.
You can always choose not to provide Whistle! with certain requested personal information, but then you may not be able to access or utilize all or part of the Site, the App and/or the Services.
Personal Information You Provide to Whistle
Personal Information Collected from Users
We collect the following types of personal information from Users:
Contact information: we collect your personal information when you contact Whistle! directly to inquire about Site, the App, and/or the Services. This may include your name, e-mail address, phone number, and other information that you choose to provide to us.
Account and profile information: we collect your personal information when you register for an account (“Account”) with Whistle!, typically after downloading the App, and when you create or modify your Account or user profile. This includes information such as your first and last name, your e-mail address, phone number, username and password.
Accessibility information: we collect information about a User’s medical condition or disability if a User voluntarily provides this information. For example, if a User provides this information to request a vehicle that accommodates a wheelchair or other form of accommodation.
User Payment information: we do not collect credit card information directly from Users. We use a third party payment processor, presently Stripe, Inc., to handle payments for us. The third party service provider will receive your credit card information when you add it to your Account.
Ratings and reviews: we collect the information you include in any feedback you provide to Whistle! through the App. This includes ratings and reviews given by riders and drivers of each other at the end of a ride, as well as feedback that you provide to Whistle! about the App. Individual reviews submitted by a User will not be visible to the User that individual has reviewed. A User’s average rating is displayed on their Account and user profile. A rider’s average rating is viewable by drivers from whom they request transportation using the App, and a driver’s average rating is available to all Users.
Other information: we collect any other personal information that Users submit directly to Whistle! on a voluntary basis. For example, you may provide information to Whistle in respect of a claim or dispute.
Additional Personal Information Collected from Drivers
We collect the following additional types of personal information from Users who are drivers, including driver applicants:
Application information and driving history: we collect personal information from individuals set up an account with Whistle!Drive and apply to provide transportation services as a driver. This includes: date of birth; mailing address; criminal record check from your local police department; driver’s abstract report; driver’s license class, number and licensing province; province of vehicle registration; vehicle information (make, model, colour, and license plate number); drivers’ insurance information and business license or permitting information, if applicable.
Photograph: we collect the photograph that drivers upload to when setting up an Account. This photograph is viewable on the drivers’ profiles to all Users
Driver payment information: we collect drivers’ bank account information, as well as information about the amounts paid to drivers by riders using the App.
Personal Information Automatically Collected When Using the Site or App
Device information: we collect your IP address, web browser type, mobile operating system, push notification tokens, application installations, mobile device carrier and manufacturer, and your mobile device identifier (e.g. IMEI numbers).
Facebook information: if you register for an Account or login to your Account via your Facebook account, Whistle will receive basic information from your Facebook profile, which includes your Facebook identifier, name, gender, and Facebook friends. If you are a driver and sign into your Whistle Account via your Facebook account, Whistle will also receive your Facebook profile photo.
Technical and usage information: we collect information about the sections of the Site and App that you visit, the date and time of your use of the Site and App and your in-media time, your actions within the Site and App, Site and App crashes and other system activity, the URLs you visited before and after using the Site, and certain content that you download from the Site and App.
Address book information: Users have the option of providing emergency contact information in their Account. Users can do so by providing the mobile phone number of an emergency contact, or by permitting Whistle to access the address book on their mobile device through the device’s privacy settings.
Geolocation and mobile sensor information: if you are a rider and have enabled location services in the App through your mobile device, we will collect the location of your mobile device when the App (Whistle!Ride) is running in the foreground or background. If you are a driver and have enabled location services in the App through your mobile device, we will collect the precise location of your mobile device when you are logged into the App (Whistle!Drive. You can choose whether to enable the location tracking feature through the settings on your mobile device. If you choose to disable access to location services through your mobile device, this means that the App will not receive location information from your device, which may affect the functionality available to you. If you are a driver User, you must enable location services while using the App in order to be able to provide ride hailing services to another User. When using Whistle!Drive and providing transportation services through the network, a driver must have location services on. If a User labels a saved address as “home”, “work”, or “other”, in the App, Whistle will collect that information.
Trip information: we collect information from both riders and drivers about their ride hailing trips, including the pick up and drop off locations, pick up and drop off date and times, trip duration, distance travelled, and amount charged. We also collect information about whether the requested ride was cancelled (and if so, by which User), and whether the ride was missed due to be rejected by the driver or timed out. We also collect information about hours driven by a driver.
Call and messaging information: we use a third party services provider, currently Twilio, to facilitate phone calls and text messages between riders and drivers who have been connected for a ride using the App. This third party services provider may collect personal information about these calls and text messages, including the date and time of the call or text message, the individuals’ phone numbers, and the content of any text message.
Cookies and tracking technology: Whistle! collects personal information when you access the Site and/or App via “cookies” and other similar tracking technologies.
USE OF YOUR PERSONAL INFORMATION
Whistle! may use the personal information that it collects for the following purposes:
Contact information: we use your contact information to contact and correspond with you directly about our relationship, and your use of the Site, App and/or Services. Whistle! may contact you to inform you about its services in different ways including by mail, email, telephone, or other means to which you have agreed. For example, we use your phone number to text you a password to create your Account and to sign-into your Account. We may use your contact information to provide you with information or services that you have requested, to respond to customer service requests, to provide you information about your requested ride including to allow drivers responding to your request for a ride to contact you, and where we have your consent to do so, to send you push notifications through the App
We use contact information from driver applicants to contact applicants regarding the status of their application, training opportunities and information about prospective work. We also use driver contact information to notify drivers about fares and service. Where we have your consent to do so, we may send you information about Whistle!’s services, including general updates and announcements, coupons, marketing purposes, and for other opportunities (see below for information on how to “opt-out” of receiving certain communications from us).
Account and profile information: we use your Account and profile information to set up provide you with access to the App and/or Services, to create and set up your Account and user profile, and to administer your use of the Site, App and/or Services.
Ratings and reviews: we use rating and review information to improve the Site, App, and/or Services, including to administer and resolve technical issues on the Site or App. We may also use this information to investigate and address User concerns. In addition, we may use this information to suspend or deactivate the accounts of Users.
Driver application information and driving history: we use this information to evaluate an applicant’s eligibility and suitability to use the App to provide transportation services to Users, and to promote the safety of Users. We also use this information for insurance coverage purposes and in the event there is a dispute or investigation.
Driver photograph: we provide drivers’ photographs to riders who are connected to the driver through the App. This enables riders to confirm the identity of a driver and to protect the safety of the rider.
Payment information: as explained above, we use a third party payment processor to handle payments for rides facilitated using the App. We use driver payment information to facilitate payments to drivers for rides that have been facilitated using the App. We use information about amounts paid to drivers by riders using the App to comply with our licensing requirements and as otherwise directed by the Board as well as in an aggregate way to analyze trends and develop pricing models.
Device, technical and usage information: we use device information to understand traffic and activity on the Site and the App, and to enable us to improve the Site, the App and/or the Services. For example, this information helps us understand whether the App is compatible with your mobile device.
Facebook information: if you register for an Account or login to your Account using Facebook, we use your basic Facebook profile information (and for drivers, profile photo) and Facebook identifier in order to set up your Account, and to facilitate your login to your Account without the need to enter a separate username and password.
Emergency contact information: if you choose to provide emergency contact information in your Account, then you will be able to give that contact access to your current location while using the App.
Geolocation information: we collect Users’ geolocation to enable riders to see where nearby drivers are located, to connect riders and drivers, to identify pick up and drop off locations, to assist with navigation, to allow riders to view the location of the vehicle while in transport, to analyze trends, and to promote the safety of Users. We used saved address information (e.g. “home”, “work”) to enable Users to hail rides more efficiently.
Trip information: we collect information this information to determine the cost of a ride, to determine fares, to calculate payments to drivers, to evaluate and monitor the App and Services, to analyze trends and determine pricing, and to improve the App and/or the Services. We also collect information this information to comply with our licensing requirements, including record keeping requirements mandated by the Board.
Call and messaging information: we may use this information for User support services (e.g. to resolve disputes between Users), for safety and security purposes, and to improve the App and our Services. As explained above, we use a third party service provider to facilitate calls and texts between riders and drivers. That service provider uses personal information to facilitate phone calls and text messages between riders and drivers, so that riders and drivers do not need to communicate using their personal phone numbers.
Cookies and tracking technology: we use this information to track the activity of Users on the Site and the App, and to modify the Site and the App to reflect a User’s preferences. Cookies enable our Site to save and retrieve information that you enter (for example, user preferences and settings). Cookies may remain on your device after you leave the Site (until the cookie expires or is deleted by you). You can disable cookies by adjusting the settings on your internet browser, however, disabling cookies may affect your ability to access some pages on the Site. We use other tracking technologies to understand how Users use the App.
In general, Whistle! may also use the personal information we collect:
To conduct data analysis, testing, research, and monitor and analyze usage and activity trends;
to promote the safety of Users;
to ensure compliance with and identify violations of the Terms of Use;
to identify and prevent fraudulent activity and to protect security of the Site and App;
to meet legal and regulatory requirements; and
to facilitate such other services and activities, as we may identify to you at the time.
If you provide us with your e-mail address and “opt-in” to receiving messages from us via the e-mail address provided, you may receive electronic communications from us from time to time. These electronic communications will provide you with our contact information and a method to opt-out and unsubscribe from receiving marketing information and/or any further communications from us. You can also opt-out of receiving further communications from Whistle! by contacting the Privacy Officer at the details below. Whistle! may use your e-mail address to communicate with you regarding important matters, such as information about your Account. You may not opt-out of receiving communications required by law, or necessary to provide you with requested services.
Whistle! will only use your personal information for the purpose for which it was originally collected, or for a use consistent with that purpose, unless you expressly consent otherwise or it is permitted or required by law.
DISCLOSURE OF YOUR PERSONAL INFORMATION
Except as described in this Policy or in other situations where we have provided you with prior notice, have obtained your consent, or are obligated or permitted by law, Whistle! will not share your personal information with third parties.
Riders and Drivers
In accordance with our licensing requirements, Whistle! will share a limited amount of personal information about riders with drivers. For example, when a rider is connected with a driver, the driver will receive the following information about the rider: first name, average rating, pickup and drop-off location, and geolocation information. The rider will receive the following information about the driver: first name, average rating, photograph, vehicle information, and geolocation information. Riders will be able to view the driver’s geolocation in real time as the driver approaches the pickup location as well as during the ride. Whistle! does not share a User’s last name, phone number or e-mail address with other Users. When a User calls or texts another User using the App, their contact number is used and provided through Twillio the third party service provider that Whistler uses to facilitates phone calls and texts? between Users. At the conclusion of the ride, Whistle! will provide the rider with an electronic receipt that contains the driver’s first name.
In the event a User shares information directly with another User (e.g. rider to driver in the course of a ride), that information is not collected, used or disclosed by Whistle! and the disclosure is in the sole discretion of the User providing the information.
Emergency Contacts
Whistle! will share a User’s name and location information with a User’s designated emergency contact, when the User requests so through the App. Whistle! may also use the emergency contact information in the case of an emergency or other situation when it appears to be in the best interests of the individual.
Third Party Service Providers
Whistle may disclose certain personal information to third party service providers with whom it has contracted to provide certain services on behalf of Whistle. Currently, Whistle uses the third party service providers set out below:
Software design and operation: we use a third party application development company, Green Coast Ventures Inc., to design and maintain the online platform that we use for the App.
Electronic communications: we use a third party email service provider, Mailgun Technologies, Inc., to send electronic communications to Users.
Phone call and text messaging: we use a third party cloud communications platform, Twilio Inc., to allow Users to call and text other Users without disclosing their last name and phone number.
Payment processing: we use a third party payment processing platform, Stripe, Inc., to facilitate payment transactions for rides facilitated using the App.
The third party service providers will have access to personal information needed to perform their functions, but are only provided the limited amount of information required to perform their services. When Whistle! uses third party service providers, it requires the providers to protect your personal information in accordance with the law and with the same or more stringent security and privacy standards than Whistle!. Any such disclosure of your personal information by Whistle! to a third party service provider will be conditional upon the information being used solely for the purpose for which it has been disclosed.
The third party service providers identified in this Policy are located outside of Canada, and your personal information may be stored, accessed or used in the United States, India, or European Union and may be subject to the laws and access by government or regulatory organizations in those jurisdictions. If you have any questions about Whistle!’s policies and practices with respect to service providers outside of Canada, including its collection, use, disclosure, and storage of personal information, you can contact the Whistle! Privacy Officer at the contact information listed in this Policy.
ICBC
We share personal information about drivers, including name and driver’s license number, with the Insurance Corporation of British Columbia to determine insurance cost and coverage, to obtain insurance coverage, and to deal with claims and investigations.
Where Required or Authorized by Law
Whistle may also disclose your personal information where authorized or required by law. For example, we may disclose your personal information to comply with a subpoena, in response to a law enforcement body with the lawful authority to obtain the information, in response to a request by the Registrar of Passenger Transportation, pursuant to an investigation into the breach of a law, or to our legal counsel.
As a condition of its license, Whistle! is required by law to disclose certain personal information about Users to the Board. For example, the Board requires that Whistle provide it with the following information:
Driver and vehicle information: vehicle registration number, province in which the vehicle is registered, driver’s licence number and province where the driver is licensed.
Trip data: trip start and end times, trip type (e.g. accessible), trip status (e.g. completed, cancelled by requester, no-show, refused by driver), pick up and drop off times and location, trip duration, trip metrics, trip distance, and trip fare.
SECURITY & PROTECTION OF YOUR PERSONAL INFORMATION
Whistle takes reasonable steps to protect your personal information. We use security arrangements to protect against unauthorized access, collection, use, disclosure, and disposal, in a manner appropriate to the sensitivity of the information. As well, Whistle will use care when destroying or disposing of personal information to prevent unauthorized access, use or disclosure of any personal information. Whistle’s employees and independent contractors with access to personal information are required to respect the confidentiality of such information.
The Site includes links to external websites. Once you leave the Site or the App this Policy does not apply. Whistle! is not responsible for the privacy practices, collection of personal information, or content of external websites. Whistle! is not responsible for the privacy practices of Stripe, Inc. nor the personal information you provide for the purposes of processing payments. Stripe, Inc.’s privacy policy can be found here: https://stripe.com/en-ca/privacy Whistle! is not responsible for any lost, stolen, or compromised user IDs, passwords or for any activity on your Account via unauthorized password activity. You should take steps to protect against authorized access to your account by, for example, choosing a robust password and keeping your login ID and password private. Whistle! is not responsible for any failure by you to secure your own devices and their access to the Internet or your use of public, unsecured networks.
RETENTION OF YOUR PERSONAL INFORMATION
Information collected by Whistle! is maintained in accordance with applicable privacy legislation and Whistle!’s retention policies and practices.
CORRECTION AND ACCESS TO YOUR PERSONAL INFORMATION
All personal information in your Account and user profile is accessible by you. You can make changes to certain personal information that Whistle holds about you, such as your contact information, by editing the information in your Account. You are responsible for keeping the personal information in your Account up to date and accurate. Certain minimum personal information must be input in your Account in order to use the App’s services. For example, riders must share their first name with drivers. Drivers must share their name, photograph and vehicle information with riders.
You can challenge the accuracy and completeness of your personal information in the possession and control of Whistle!. In appropriate circumstances, Whistle! will amend the information. It is your responsibility to provide any updates to your personal information to Whistle! in writing.
You may request access to your personal information and/or correction of that information by contacting Whistle! in writing at the contact information noted below, with sufficient detail to enable Whistle! to identify the personal information being sought. When you contact Whistle!, we may ask for further information to confirm your identity and the nature of the information being sought.
After we receive your request for access to personal information, Whistle! will provide you with an estimate of when you can expect a response. In some cases, Whistle! may need additional time to respond to a request, in which case we will provide you with written notice of the extension. Please note that in some cases, Whistle! may not provide access to personal information that we hold about you, such as where the denial of access is authorized by law. There are also cases where Whistle! may be legally required to refuse access to personal information. If Whistle! denies your request for access to personal information, we will advise you of the reason for the refusal, and will provide the name, title, and contact information of the designated person who can address the refusal.
Whistle! may charge a reasonable fee according to the cost required to retrieve and provide access to the requested information. We may provide an estimate of the fee in advance and in some cases, will require a deposit for all or part of the fee.
QUESTIONS AND CONCERNS
Questions or concerns regarding this Policy, including the collection of your personal information, can be directed to the Whistle Privacy Officer, who is responsible for ensuring Whistle’s compliance with this Policy. You can contact the Privacy Officer using any of the following methods:
Mailing Address: PO Box 1024, Tofino, B.C. V0R 2Z0
Telephone: 778.770.1110
Email: privacy@whistle.ca
Whistle! takes any complaint about our privacy practices seriously. Whistle! will investigate all complaints. If Whistle finds a complaint justified, we will take the necessary steps to resolve it. The complainant will be informed of the outcome of the investigation regarding any complaint. If you are not satisfied with Whistle!’s response to a complaint, you may have options to exercise various complaint procedures, including with the relevant Privacy Commissioner or regulatory authority.
CHANGES TO THE POLICY
Whistle may update this Policy from time to time by posting a new version of the Policy on the Site and the App. If there are significant changes made to the Policy, we may notify Users in advance through the App or by e-mail. Whistle!’s collection, use, disclosure, and retention of your personal information will be governed by the version of the Policy in effect at that time. We suggest that you review this Policy periodically.
Last updated: December 19, 2019