Xperigo Legal

Privacy Policy


Club Auto Roadside Services Ltd., dba XPERIGO (“XPERIGO”) is bound by the privacy laws and statutes governing all of the various jurisdiction in which it operates, including applicable Federal and local legislation.


Website Privacy Policy

XPERIGO is committed to protecting the privacy of visitors to its website. Our privacy practices are detailed in herein.


Collection of Personal Information

We do not gather personal information such as your name, phone number, or email address unless you supply it to us, usually through our commercial partners or through contacting us via e-mail, telephone, fax, regular mail or registering in a secure portion of the site. The choice to provide us with personal information is always yours.


Server/Web Logs

XPERIGO and participating vendors maintain server logs and web logs which automatically collect and log all incoming traffic to our website including your Internet Protocol (IP) address. However, neither we, nor our vendors, attempt to link these addresses with the identity of individuals visiting our site. XPERIGO maintains and analyzes the web logs and web traffic. XPERIGO maintains the server logs but does not make any attempt to link these addresses with the identities of individuals.


Cookies

Our website may set and access “cookies” on your computer. Cookies are text files placed in your computer’s browser to store preferences. We may use cookies to understand website usage and to improve the website’s content and offerings. For example, we may use cookies to personalize your experience (e.g. to recognize you by name when you return to our site) or save your password in password-protected areas. We may also use cookies to offer you access to programs and services. Cookies on our website do not contain any personal information and are only used to facilitate the operation of our website.


Disclosure and Use of Personal Information

Website visitor information is not disclosed to anyone outside of our organization. It may be used by XPERIGO personnel if necessary, e.g. to respond to a request from you.


Third-party sites

This website contains links to other sites. We are not responsible for the content or the privacy practices of other websites and encourage you to examine each site's privacy policy and make your own decisions regarding the accuracy, reliability and correctness of material and information found. For questions or comments regarding this privacy statement or our privacy practices, please contact our Privacy Officer at: privacyofficer@xperigo.com


Our Commitment to Your Privacy

To provide its services, XPERIGO needs to collect, use and disclose your personal information. You have a right to know how we collect, use and disclose your personal information. You have a right to expect that we will use reasonable means to keep your personal information accurate, confidential and secure.


Protection of Personal Information

XPERIGO employs stringent privacy and security measures, including technical, contractual, and corporate measures to protect the personal information in its custody and control from inappropriate disclosure to foreign governments.


The Principles that Guide Our Privacy Program XPERIGO observes privacy principles such as those set out below:


I. Accountability XPERIGO is responsible for protecting personal information in its custody or under its control in compliance with applicable federal and local legislation, guidelines and rules. XPERIGO has identified and designated a Privacy Officer to be responsible for implementing the privacy program and ensuring compliance with applicable legislation and rules.


II. Openness XPERIGO develops and follows privacy and security policies and practices that are compliant with legislation and provincial rules. Information about XPERIGO’s privacy practices are made publicly available.


III. Consent for the Collection, Use and Disclosure of Personal Information The knowledge and consent of the individual are required for the consent, use, or disclosure of personal information, except where inappropriate. In order to be knowledgeable, XPERIGO will make reasonable efforts to ensure that individuals are advised of the purposes for which information will be collected, used or disclosed. The purposes must be stated in such a manner that the individual can reasonably understand how the information will be used or disclosed.


IV. Identifying Purposes At or before the time personal information is collected, XPERIGO will identify the purposes for which personal information is collected.


V. Limiting Collection of Personal Information The collection of personal information will be limited to that which is necessary for the purposes identified by XPERIGO. Information will be collected by fair and lawful means.


VI. Limiting Use, Disclosure and Retention of Personal Information XPERIGO uses, discloses and retains personal information for purposes consistent with the purpose for which it was collected. Use and disclosure for other purposes is by consent of the {L1695369.1} individual or as authorized by law. Personal information will be retained only as long as necessary for the fulfillment of the purposes.


VII. Accuracy XPERIGO will make reasonable efforts to ensure that personal information collected, used or disclosed by or on its behalf is accurate and complete, as is necessary for the purposes for which it is to be used.


VIII. Safeguards XPERIGO protects personal information in its custody or control by deploying security measures and practices to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal or destruction. XPERIGO uses contractual or other means to provide a comparable level of protection while the information is in a service provider’s possession, including appropriately executed business agreements, when deemed necessary.


IX. Right of Access Individuals have a right to access information that XPERIGO holds about them, subject only to limited and specific exceptions. Individuals who believe there is an error or omission in their personal information have a right to request correction or amendment of the information.


X. Compliance Challenges Individuals are encouraged to bring any concerns or issues regarding privacy to the Privacy Officer for discussion and response.


Why Do We Collect Personal Information?

What is Personal Information? Personal information is any factual or subjective information, recorded or not, about an identifiable individual. In general, XPERIGO collects personal information directly from you or from a person acting on your behalf. Personal information includes, for example, your name, address, telephone number, vehicle identification number (VIN), e-mail address, date of birth.


Why do we collect Personal Information?

XPERIGO collects and uses personal information for various purposes in order to provide services to you. The primary purposes for which XPERIGO collects and uses personal information in each of XPERIGO’s main business areas include:


i) Corporate services

Roadside Assistance: To provide accounting, emergency service calls, towing services, travel planning services, traffic accident emergency services, trip-interruption services, motorist legal services, hazardous weather services, stolen vehicle services, vandalism services and fire damage services.


Surveys: To provide accounting and outbound survey services. Personal opinion data is received by email and text message and electronically entered onto client’s file.


XPERIGO’s internal and external purposes: For the purposes of accounting, new contractor and supplier authorization, complaint resolution and external corporate client reports.


• For planning purposes.

• To obtain payment for services.

• For quality and risk management activities and for client satisfaction surveys.

• To meet legal and regulatory requirements.


What are your privacy rights?

You or a person authorized on your behalf have the right to:

Be informed of the existence of and be provided access to your personal information in the custody and control of XPERIGO, subject to limited exceptions


• Request changes or corrections to inaccurate or incomplete personal information.

• Subject to privacy laws, withdraw your consent for the collection, use or disclosure of your personal information at any time.

• Inquire about how we handle personal information.

• Complain if you have concerns about the way we handle your personal information.


How do you contact the Privacy Officer?

XPERIGO has designated Privacy Officers to facilitate compliance with applicable federal and provincial legislation and this Policy. If you have an inquiry or would like more information about our information practices, you may contact the privacy officer at: privacyofficer@xperigo.com


Who else can I contact if I have a privacy complaint?

You have the right to make a complaint to federal or provincial privacy oversight bodies if you have concerns about our privacy practices.