Privacy Policy
This Privacy Policy applies to your access or use of the website located at www.vsdrive.ca (the “Website”) and the VSdrive mobile application (“App”). The Website and the App are hereinafter collectively referred to as “the Platform.” The Platform is owned and operated by VS Auto Management Inc, a Company formed and operating in accordance with the laws of Canada from its head office in British Columbia (the “Company,” “VSdrive,” “we,” “us” or “our”).
The Company is the data controller of the personal data collected from you during your use of the Platform.
This Privacy Policy informs you how we collect, use and share your personal data, and your rights as a data subject. We only process your personal data in compliance with applicable laws and regulations in the jurisdictions where we offer the Platform, including but not limited to the General Data Protection Regulation 2016/679 (“GDPR”).
You are advised to carefully review this Privacy Policy prior to accessing the Platform. If you do not agree with any provision of this Privacy Policy, please do not access the Platform or otherwise use the Service.
Table of Contents
-
Definitions
-
How do we collect and use your personal data?
Personal data submitted directly by you
Automatically collected data
Other Lawful Basis
3. Disclosing your personal data
Sharing data between users
Our Service Providers
Merger or Acquisition
Legal requests
User Content Data
Analytics Tools
Any other data
4. Security of your data
5. Transfer of data
6. Retention of data
7. Data Subject Rights
8. Compliance With PIPEDA
9. Children's Privacy
10. California Residents Rights
11. Third-Party Links
12. Changes to this Privacy Policy
13. Contact Us
1. Definitions
The following words, wherever used in this Privacy Policy, shall have the meaning as defined hereunder:
Account Holder：refers to Owners and Renters who sign up for the user account on the Platform, either on his/her own behalf or on behalf of a legal entity.
Data Controller：has the meaning as defined in Article 4(7) of the General Data Protection Regulation.
Data Subject：refers to any individual who accesses/uses the Platform, registers a user account or otherwise interacts with the Company.
Owner：refers to a user who lists his vehicle on the Platform for rent.
Personal Data：has the meaning as defined in Article 4(1) of the General Data Protection Regulation.
Processing：has the meaning as defined in Article 4(2) of the General Data Protection Regulation.
Renter：refers to a user who is the primary driver for a Booking and/or any secondary driver authorized by VSdrive.
Services：means the Platform, including all related resources, software features/functionality, support and other services provided by the Company to you.
User：refers to an account holder on the Platform.
User Account：means the Platform account provided by the Company to a user, which enables the user to securely log in to the Platform and use the Service.
User Content：shall have the meaning as defined in the VSdrive Marketplace Terms of Service.
2. How do we collect and use your personal data?
We collect your personal data in multiple ways, including personal data you submit when you use our Service and personal data that we automatically collect from your use of the Platform.
We will only collect and process your personal data if we have a lawful basis for processing such data, which may include your consent, our contractual obligations/provision of the Services or our legitimate interests.
The exact elements of personal information we collect from you may also depend on whether you are using the Service as an Owner or Renter.
We collect personal data from you primarily in the following ways:
Personal data submitted directly by you
-
User Account Registration and Profile Data (“Account Data”)
Your Account Data includes all personal data that you provide us with when you sign up for a user account, including but not limited to your full name, age, email address, driver’s license, phone number, and address. We may also request you to authorize us to access your driving records.
How do we use your Account Data?
We use your Account Data for purposes including but not limited to:
-
Creating your user account on the Platform;
-
Enabling you to make use of the Service; and
-
Contacting you as and when required;
Legal basis
Our legal basis for processing your Account Data is the performance of our contract with you.
● Verification Data
We may request you to provide us with verification data which may include but is not limited to a copy of your driving license, driving records, insurance information and other similar data.
How do we use your Verification Data?
We use your Verification Data for purposes including but not limited to:
-
Verifying your information that you submit through the Platform during account creation and use of the Service;
-
Detecting and preventing fraud or other similar unauthorized activities; and
-
Assessing the risks associated with your use of the Service.
Legal basis
Our legal basis for processing your Account Data is our legitimate interest.
-
User Content Data
Your User Content Data includes any data you create, post or upload on the Platform, including but not limited to data contained in your vehicle listing and your ratings and reviews. User Content Data includes text, images, audio and videos or other similar files/information you share through your User Account on the Platform.
How do we use your User Content Data?
We use your User Content Data for purposes, including but not limited to:
-
Listing your vehicle on the Platform;
-
Delivering, maintaining and improving our Service;
-
Enabling users to interact with your User Content on the Platform;
-
Detecting and preventing fraud or other similar unauthorized activities.
Legal basis
Our legal basis for processing your User Content Data is the performance of our contract.
-
Communication Data
Your Communication Data includes the content of any messages you send or receive through the Platform, including but not limited to any messages you send or receive from the Company and other users.
How do we use your Communication Data?
We use your Communication Data for purposes, including but not limited to:
-
Delivering, maintaining and improving the Service to our users;
-
Responding to your support requests/enquiries and resolving any issues;
-
Detecting and preventing fraud or other similar unauthorized activities, including spam.
Legal basis
Our legal basis for processing your Communication Data is our legitimate interest.
-
Transaction Data
When you conduct any transactions through the Platform, such as booking/renting a vehicle, we will collect some data from you. Your transaction data that we collect includes the amount of your transaction (“booking fee”), the date and time of the transaction, your payment details (all payment details are stored and processed by Stripe Inc).
How do we use your Transaction Data?
We use your Transaction Data for purposes, including but not limited to:
-
Processing your transaction, including billing the Renters and distributing revenue to the Owners (if applicable);
-
Sending relevant notices relating to your transaction;
-
Conducting any relevant investigations; and
-
Detecting and preventing fraud or other similar unauthorized activities and transactions.
Legal basis
Our legal basis for processing your Transaction Data is the performance of our contract with you.
-
Direct Marketing Data
When you subscribe to our mailing list, we collect your full name and your email address.
How do we use your Marketing Communication Data?
-
We use your marketing communication data to send you our newsletter and other promotional material that we believe you would find interesting.
Legal basis
Our legal basis for sending you direct marketing communication is your consent. You may withdraw your consent at any time. If you unsubscribe from our mailing list, we will immediately stop processing your personal data for our direct marketing purposes.
Automatically collected data
When you access and make use of our Platform, we may automatically collect some data about you, such as:
-
Usage Data
When you use our Platform, we may automatically collect data such as the pages you visit on our Platform, the date and time of your visits, the time you spend on the Platform, your searches, activity history, and other similar data.
How do we use your Usage Data?
We use this data for purposes, including but not limited to:
-
Providing our Platform;
-
To improve our Service offering, your user experience and create new services; and
-
To guide our marketing strategy.
Legal basis
Our legal basis for processing this data is our legitimate interest.
-
Location Data
When you make use of the Services, we may automatically collect information about the location of your device.
How do we use your Location Data?
We use this data for the following purposes:
-
To make certain service features available to you;
-
To display location-relevant content to you.
You can disable the location services on your device and refuse the collection of location data when requested.
Legal basis
Our legal basis for processing this data is your consent.
-
Device Data
We automatically collect some data from you when you access our Platform, including but not limited to your Internet Protocol (IP) address, your browser type and version, hardware mode of your device, your time zone setting and location permissions, and other similar information.
How do we use your Device Data?
We use this data for purposes, including but not limited to:
-
To make the Service available on your device;
-
To improve your user experience;
-
Detecting and preventing fraud or other similar unauthorized activities;
-
To send you system updates and alerts.
Legal basis
Our legal basis for processing this data is our legitimate interest.
-
Vehicle tracking data
Some luxury vehicles may have GPS tracking devices installed which may enable the Company and/or the Owner to collect information including but not limited to the GPS location of the vehicle.
How do we use the Vehicle tracking data?
We may use this data to identify the location of the vehicle, identify any unsafe driving conduct such as speeding etc.
Lawful basis
Our lawful basis for processing this data is your consent.
-
Cookies Data
We also collect some data through the use of cookies, pixels, clear gifs, tags and other similar technology when you visit our Platform. Please note that we currently do not respond to “DNT” signals.
How do we use Cookies Data?
We use this data for the following purposes, including but not limited to improving our understanding of how you interact with our Platform. You can reject cookies by changing your browser settings at any time, as well as by deleting cookies.
Lawful basis
Our lawful basis for processing this data is your consent.
Other Lawful Basis
We may also use any information we collect from you for other lawful purposes such as our legal compliance and/or to assert our legal rights or defend any claims.
3. Disclosing your personal data
We may disclose your personal data as outlined hereunder:
-
Sharing data between users
The Platform enables Owners to list their vehicles for rent and Renters to book vehicles listed on the Platform. Owners and Renters understand and agree that when they enter into a vehicle booking transaction through the Platform, some of their information will be disclosed by the Company to the other party to the transaction. The Company will only disclose the information necessary to facilitate the transaction.
-
Our Service Providers
We may share and disclose your personal data with third-party service providers that we engage during the performance of our business operations, such as web hosting, payment processing, email distribution, insurance, marketing and customer support services. For the avoidance of any doubt, we will only disclose your personal information that is necessary for our Service Providers to perform their functions on our behalf. Our Service Providers will only use your personal information as authorized by us, and in no event will they be allowed to use it for any purpose other than those specified in this Privacy Policy.
-
Merger or Acquisition
If we enter into any discussions to sell or otherwise transfer any part or whole of our business, we reserve the right to disclose your personal information as part of commercial due diligence or transaction that we enter into.
-
Legal requests
If we receive a valid legal request for disclosure of your information, such as a subpoena, we will be required to disclose your personal information to such requesting body for compliance with the law.
-
User Content Data
You understand that your User Content data is publicly visible to users on the Platform, as well as your public profile information such as your username, profile image. You also acknowledge and agree that your User Content data and associated public profile data may be indexed by search engines and discoverable by anyone on the world wide web.
-
Analytics Tools
We may also make use of third-party analytics tools to evaluate the usage of our Platform. These third-party analytics tools may use cookies, pixels, and web beacons to collect some of your data to provide the analytics services to us.
-
Any other data
We may share any other data about you with third parties, with your consent and on your instructions.
4. Security of your data
We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. Although we will do our best to protect your personal information, you acknowledge that the transmission of personal information over the internet is never completely secure, which is why we cannot offer any guarantees as to the absolute security of your personal data. You should only access the services within a secure environment.
5. Transfer of data
The Company is operating from Canada, and we may sometimes engage processors who are located in countries different from where your personal data is collected. Whenever we transfer your data to a third country that does not offer adequate personal data protection, we will take appropriate steps to ensure that your personal data receives the same level of protection as provided by Canada or your country of residence.
6. Retention of data
We will only retain your personal data on our database and servers as long as it is required for delivering our Service to you in accordance with our Agreement with you and for our business and legal compliance purposes. We will not retain your personal data longer than we are required to keep it for the purpose for which we initially collected it. Once we no longer have a lawful basis for processing your personal data, we will securely delete it or anonymize it so it cannot be linked back to you as an individual.
7. Data Subject Rights
You have the right to access and edit your personal information that we hold for you. You can exercise your right by signing in to your user account on the Platform or sending us a data subject request. In some circumstances, you may also request the deletion of your personal data. Where our legal basis for processing your personal data is your consent, you have the right to withdraw your consent. You can send your data subject requests to us at support@vsdrive.ca, and we will respond to your request within 30 days.
8. Compliance With PIPEDA
We adhere to the principles of privacy as set forth in the Personal Information Protection and Electronic Documents Act (PIPEDA). Accordingly, we have a designated Privacy Officer to ensure that we are accountable for any and all personal information of our users that we hold.
We practice complete transparency, and we do not collect any personal information from our users without informing them of the purpose for the collection of their personal information, and we do not ever do so without our users’ express consent.
Except where we are required to disclose any personal information by law, we will never disclose or use any of our users' personal information in a manner other than as indicated at the time when we obtained such information.
We take all reasonable steps to keep our users' personal information accurate, complete, current and relevant based on the information that we are provided by our users.
We also take all reasonable and commercially viable measures to protect our users' personal information.
Our users may at any time access their information and query how we manage and protect their personal information by contacting us.
9. Children's Privacy
We are committed to protecting children’s privacy. The Platform does not allow users under the age of 19 years to sign up for a user account. If you believe that a child has provided his/her personal information to us, please contact us, and we will investigate the matter and take appropriate action.
10. California Residents Rights
As a California resident, you have specific rights relating to your information, including the right to:
-
Request access to the specific personal data that we have collected about you in the preceding year. You also have the right to request information about our privacy practices, how we collected your personal data, parties with whom we share your personal data. You may make specific requests to exercise these rights by logging into your user account on the Platform or by sending a support request to us. Please note that we have provided comprehensive information to address these rights in this Privacy Policy. However, if you have any additional requests, you may contact us at the contact email provided at the bottom of this Privacy Policy.
-
Request deletion of your information (available in limited circumstances).
-
Instruct the Company not to sell your information to any third party by exercising your right to opt-out.
-
Not to be discriminated against for exercising your rights as outlined in this provision.
11. Third-Party Links
Our Platform may contain links to third-party websites that are not owned or operated by us. Should you decide to click on any such third-party links, you will be directed to such a third party’s website. These third-party websites are governed by their own Terms and Conditions and Privacy Policy. We encourage our users to review the third-party Terms and Privacy Policy before making use of such services. The presence of any third-party links on our Platform does not constitute an endorsement or recommendation of such a third party, and we cannot be held responsible for such a third party’s actions.
12. Changes to this Privacy Policy
From time to time, we may amend this Privacy Policy to reflect our new privacy practices and commitment to compliance with applicable privacy laws and regulations. We will post the updated Privacy Policy on this page and notify you of such updates by changing the last updated date on the top or by sending an email. You should review this Privacy Policy regularly to ensure that you are familiar with any changes. You understand and accept that your continued use of the Platform after the update's effective date will be deemed your tacit acceptance of any updated privacy practices.
13. Contact Us
If you have any questions, comments, or inquiries regarding this Privacy Policy, please contact us at:
VSdrive
4170 Still Creek Drive
Suite 200
Burnaby BC V5C 6C6
Canada
Email: contact@vsdrive.ca