Last Updated: 16/07/2021

By entering into this Agreement, you acknowledge and agree to the terms of this Privacy Policy and that this Privacy Policy forms part of the Agreement between you and us.

This Privacy Policy describes how we collect, use, disclose, retain, dispose of, and protect personal information in the course of providing services to you. Our Privacy Policy has been designed to comply with Canada’s Personal Information Protection and Electronic Documents Act, the Act Respecting the Protection of Personal Information in the Private Sector and other applicable privacy laws relating to the protection of personal information (collectively, “Privacy Legislation”).

We are committed to protecting your personal information. We have established practices and procedures to ensure that this information is appropriately safeguarded.

By accessing our services, you accept the terms of this Privacy Policy and consent to our collection, use, disclosure and retention of your personal information as described herein.

Our data processing practices may vary among the jurisdictions in which we operate in order to comply with applicable legal requirements. Please note that certain rights, requirements, and disclosures in this Privacy Policy may be subject to exemption or otherwise may not apply to you based, for example, on applicable law or regulations. If you reside in a relevant geographic location, please see the Region Specific Disclosures section for more information.

  1. Collection of Personal Information

    In this Privacy Policy, “personal information” or “personal data” means any information about an identifiable individual as defined in
    applicable Privacy Legislation and includes information such as home address and telephone number, date of birth, age, and driver’s license.
    It does not include business contact information of individuals that communicate with us in relation to their business, employment or
    profession.We collect the following types of personal information:
    Personal information that you give us:

    • Identity Data. When you reserve the services, we require certain personal information, such as name, date of birth, street addresses,
      phone numbers, driver’s license number, date of issuance and issuing country and/or province and/or state, driving record, insurance
      information, and other forms of personal information.
    • Payment data. When you make a reservation, we collect your digital payment details, and payment card number, which may be processed
      and stored by one or more third party payment service providers or digital payments companies.
    • Communications. When you communicate with us, we may collect information about your communication and any information you choose to

    Personal information we automatically collect

    • Usage data. We may collect information about your interactions with the services, such as your searches, bookings, navigation paths
      between pages, information about your activity on a page or screen, access time and duration, and other actions relating to the
    • Location data. When you use certain features of the services, we may collect information about your approximate location. When you opt
      in to use our location sharing feature, we may collect the precise location information of your mobile device.
    • Device data. We may collect information about your device, such as its manufacturer and model, browser type, screen resolution, IP
      address, and unique device identifiers.
    • Trip data. We may collect information related to the trips you take using the services.
    • In-vehicle device data. We may collect certain information from the in-vehicle computer, which may include, GPS location, car battery
      voltage, odometer reading, malfunction indicator lamp (e.g., a check engine light), speed, door state (e.g., locked/unlocked), and
      engine state (e.g., stopped/running).
    • Cookies and similar technology. We (including companies we work with) may place small data files on your computer or other device you
      use to reserve the services. These data files may be cookies and other local storage provided by your browser or associated

    Personal information we collect from third-party sources.

    • Third-party services. If you choose to log in to our services through a third-party site or service, the third-party service provider
      may send us your profile information from that provider. You agree that we may collect, store, and use this information provided by
      third-party service providers in accordance with this Privacy Policy.
    • Background check services. To the extent permitted by applicable laws, we may use your personal information to collect background
      information about you from public records, background check providers, other screening services and other third-party data providers.
  2. Use of Personal Information

    We will use, store, and process your personal information for the following reasons and purposes:

    • To provide and improve the services and for security and safety purposes. For example, we may use your information to provide the
      services, including to provide you with customer support, send you administrative messages, reminders, technical notices, updates,
      security alerts, and information requested by you, facilitate your login to your Robile account using third-party identity and access
      management providers, process transactions and send notices about your transactions, customize your user experience; manage your
      referral invitations, rewards, etc., and send you requests for reviews, for fraud detection and prevention, and for any other purpose
      you authorize at the time of collection.
    • For research and development. For example, we may use your personal information to analyze and improve the services and to develop new
      services. We may also use your personal information to create aggregated or other anonymized data, which we may share with third
      parties for any lawful business purposes.
    • For direct marketing and advertising to you and interest based advertising.
    • For security and safety. For example, we may use your personal information to authenticate any information that you provide us,
      collect fees, detect, prevent, and/or remediate fraud, abuse, security incidents, or other violations of this Agreement, to identify
      unsafe driving behavior, and to conduct investigations and risk assessments.
    • To comply with law. For example, we may use your personal information as we reasonably believe is appropriate in order for us to
      comply with applicable laws, lawful requests, and legal processes.
    • With your consent. We may use your personal information if you consent to such use.
  3. Disclosure of Personal Information

    We will disclose your personal information to the following groups:

    • Service providers. We may share personal information with service providers who support the operation of the services or who need
      access to such information for bona fide business purposes.
    • Professional advisors. We may disclose personal information to our professional advisors where necessary in the course of the
      professional services that they render to us.
    • Business transfers. We may transfer or license your personal information in connection with a business transaction (or potential
      business transaction) such as a license, corporate divestiture, merger, acquisition, reorganization, or sale of assets, or in the
      event of bankruptcy or dissolution.
    • Legal Requests. We may disclose your personal information to courts, law enforcement, governmental or tax authorities, or third
      parties, if we reasonably believe that disclosure is appropriate in order for us to comply with applicable laws, lawful requests, and
      legal processes

    As noted above, certain vehicle information such as location, speed and distance travelled is collected by, and transmitted to, the car
    manufacturer. Such vehicle information is processed in accordance with the car manufacturer’s privacy policy.

  4. Security

    We employ a number of technical, physical, and organizational measures designed to protect personal information against unauthorized access,
    destruction, or alteration while it is under our control. However, no method of transmitting or storing information can be 100% secure and we
    cannot guarantee the security of your personal information.

  5. Where We Store Personal Information

    The services are controlled and operated from Canada and the personal information we collect from you will be used, stored, and processed in
    Canada. Please note that certain vehicle information is collected by the vehicle manufacturer and may be stored outside Canada. This
    information is subject to the laws of the third party’s jurisdiction, including laws with respect to disclosure of such information, and may
    be accessible by regulatory authorities in other jurisdictions.

  6. How We Obtain Your Consent To The Collection, Use And Disclosure Of Your Personal Information

    By using our websites, purchasing our services and continuing to do business with us, you are consenting to the collection, use and disclosure
    of your personal information for the purposes identified in this Privacy Policy. We will not, as a condition to the supply of services,
    require you to consent to the collection, use or disclosure of your personal information beyond that required to fulfill those purposes.

  7. Withdrawing your Consent

    You may withdraw all or part of your consent for us to collect, use or disclose your personal information in accordance with this Privacy
    Policy at any time upon reasonable notice to us in writing, subject to legal or contractual restrictions. The withdrawal of your consent may
    affect our ability to continue to provide you with the services that you have or would like to receive.
    If you have previously agreed to receive promotional emails from us, you may also opt out of receiving promotional emails from us by following
    the instructions in those emails. If you opt out, we may still send you non-promotional communications, such as messages about your account or
    our ongoing business relations.

  8. Retaining and Disposing Of Information

    Your personal information is maintained on our networks or on the networks of our service providers and car manufacturers. Your information
    may also be stored by us or on behalf of us in a secure off-site storage facility. To satisfy regulatory requirements, we will retain personal
    information for at least seven years (unless there are legal requirements that require its further retention) after which all documentation
    will be destroyed in a manner commensurate with its sensitivity.

  9. Disclosure of Personal Information

    We will disclose your personal information to the following groups:

    Access to Personal Information

    You may request a copy of your personal information from us pursuant to any information access rights that you may have under applicable law.
    Should we receive such a request, we may request proof of your identity in order to verify your access request.

  10. Sensitive information

    We ask that you do not disclose to us any sensitive information (such as social insurance numbers, passports, information related to racial or
    ethnic origin, or health) unless specifically requested by us.

  11. Responding To Inquiries And Complaints

    If you have questions or complaints with respect to our privacy policies and practices or if you wish to request access to, or correction of,
    your personal information under our care and control, please contact the Privacy Officer at:
    [Insert Address, email address and a phone number]
    Inquiries or complaints will be dealt with promptly. The Privacy Officer will acknowledge your query, investigate and provide you with a
    response within 30 days.

  12. Right To File A Complaint

    If you believe the privacy laws relating to the protection of your personal information or our Privacy Policy have not been respected, you may
    file a complaint with our Privacy Officer at the address listed above. We will investigate all complaints. If, after an investigation, your
    complaint is deemed justified, we will take appropriate steps to correct the situation, including, if necessary, amending our policies and
    practices. If you are not satisfied with the results of the investigation or the corrective measures taken by us, you may exercise the
    remedies available under law by contacting the Office of the Privacy Commissioner of Canada at the address below:
    Office of the Privacy Commissioner of Canada
    30 Victoria Street
    Gatineau, QC K1A 1H3

  13. Changes To Our Privacy Policy

    Subject to applicable law, we reserve the right to modify or supplement this Privacy Policy at any time. If we make changes, we will notify
    you by posting the updated policy and revising the “Last Updated” date. We encourage you to review this Privacy Policy whenever you use our
    services and to stay informed about our information practices and how you can help protect your privacy.

  14. Region Specific Disclosures

    • United Kingdom

      Notice to Individuals in the United Kingdom, a member state of the European Union or the European Economic Area
      Our legal bases for processing personal information are:

      • To comply with legal obligations;
      • To perform contracts;
      • To pursue our legitimate interests, including, engaging in commerce, offering the services, preventing fraud, correcting and
        addressing technical, service or security problems, ensuring information and network security, direct marketing and
        advertising, and complying with industry practices; and

      Data Retention

      We retain personal information pursuant to our records retention program, for as long as is necessary for the purposes set out in this
      Policy, unless a longer period is permitted or required under applicable law or is needed to resolve disputes or protect our legal
      rights. We
      may retain anonymized, aggregated data indefinitely, to the extent permitted under applicable law.
      The criteria used to determine the period for which personal information about you will be stored varies depending on the legal basis
      which we process such personal information:

      • Legitimate Interests. For a reasonable period of time based on the particular interest, taking into account the fundamental
        and the rights and freedoms of the data subjects.
      • Contractual Necessity. For the duration of the contract plus some additional limited period of time that is necessary to
        comply with
        law or that represents the limitation period for legal claims that could arise from the contractual relationship.
      • Legal Obligation. For the duration of time we are legally obligated to keep the information.
      • Consent. For the period of time necessary to fulfill the underlying agreement with you, subject to your right, under certain
        circumstances, to have certain personal information about you erased (see Data Subject Rights below).

      Automated Decisions

      To the extent permitted by applicable law, we may collect data in an automated manner and make automated decisions, including using
      learning algorithms, about individual users of the services in order to provide or optimize the services offered and/or delivered, for
      security or analytics purposes, and for any other lawful purpose. To the extent permitted by applicable law, we may use automated
      for example, to display advertisements and offers based on the individual’s preferences.

      International Data Transfers

      The services may be provided using resources and servers located in various countries around the world, including Canada, the United
      and other countries. Therefore, personal information about individuals or customers may be transferred, processed and stored outside
      country where the services are used, where the level of data protection may not be deemed adequate by the European Commission. If you
      located outside of these jurisdictions, the transfer of personal information may be necessary to provide you with the requested
      products, and services and/or to perform any requested transaction. By using any portion of the services, you acknowledge and consent
      to the
      transfer of your information as set forth herein.

      Data Subject Rights

      Under certain circumstances, under applicable data protection law you have the right to.

      • Access. Individuals have the right to know if we are processing personal information about them and, if so, to access and
        obtain a
        copy of personal information about them, as well as information relating to the processing of that data.
      • Rectification. Individuals have the right to have us correct or update any personal information about them that is inaccurate
        incomplete without undue delay.
      • Restriction. Individuals have the right to restrict or limit the ways in which we process personal information about them
        where the
        accuracy of the personal information is contested by them, where data has been obtained by us unlawfully, where the individual
        objected to our processing of the data (see right of objection below) and we are considering whether to cease processing, or
        where we
        no longer need to process the personal information.
      • Objection. Individuals have the right to object to our processing of their personal information where we are relying on
        interests as our legal basis and their rights override our legitimate interests in processing their personal information.
        also have the right to object to our processing of their personal information for direct marketing purposes.
      • Withdrawal of Consent. Where we rely on consent as the basis for processing personal information, individuals have the right
        withdraw their consent.
      • Erasure. Individuals have the right to request deletion or erasure of their personal information in a number of circumstances
        required by law. These include where we no longer require the personal information for the purposes for which it was
        collected, the
        individual has withdrawn consent or, where we are relying on legitimate interests as a legal basis, and the individual’s
        override our legitimate interests.
      • Portability. Individuals have the right to obtain a copy of the personal information we hold about you in a structured
        machine-readable format and to have it transmitted to another controller. This right only occurs where we are relying on your
        or performance of a contract as our legal basis and the processing is carried out automatically.
      • Make a Complaint. Individuals also have the right to make a complaint about our personal information handling practices to
        their local
        data protection authority. We would, however, appreciate the chance to deal with your concerns before you approach the data
        authority, so please contact us in the first instance.

      To assert one of your legal rights described in this Section, or if you have questions about this Section or our data handling
      please contact us per the details provided below and provide sufficient details so that we can respond appropriately. We will process
      requests in accordance with applicable law and within a reasonable period of time. We may need to verify the identity of the
      submitting a request before we can address such request. If the request relates to data our customers collect and process through the
      services, we will refer the request to that customer and will support them in responding to the request. For Robile customers, certain
      information may be reviewed, corrected and updated by logging into your online account and editing the profile information.

      Compelled Disclosures

      We may be required to disclose personal information in response to lawful requests by public authorities, including to meet national
      security or
      law enforcement requirements.

      Data Protection Contact

      Our Data Protection Contact for the personal information collected in connection with the services is:

    • California Privacy Rights

      We do not sell personal information, or otherwise provide personal information to third parties, other than service providers
      information to perform services for us on our behalf.
      We disclose the following categories of personal information for a business purpose:

      • Identifiers;
      • Commercial information;
      • Information relating to Internet activity or other electronic network activity;
      • Geolocation data;
      • Audio, electronic, or visual information;
      • Characteristics of protected classifications under California or federal law; and
      • Other information.
    • Your Rights Under California Law

      If you are a California resident, subject to applicable law, you have the following rights under California law with respect to your personal

      • Right to Know. You have the right to request what personal information we collect, use, disclose, and/or sell, as applicable.
      • Right to Delete. You have the right to request the deletion of your personal information that is collected or maintained by us.
      • Right to Non-Discrimination. You have the right not to receive discriminatory treatment by us for the exercise of the privacy rights
        described above.

      You may also authorize someone to exercise the above rights on your behalf. In order to authorize another person to exercise your rights under
      California law, with respect to your personal information, you must (i) provide written permission to the person acting on your behalf, and
      you must verify your identity directly with us by emailing ■. If we have collected information on your minor child, you may exercise the above
      rights on behalf of your minor child.

      The above rights are subject to our being able to reasonably verify your identity and authority to make these requests. These rights are also
      subject to various exclusions and exceptions under applicable laws. The process used to verify requests, including any information that must
      provided, is that the applicable individual is required to email ■, from the email address that we have on file for the person making the
      and state in writing that they are the correct individual and are making the request.

      If you are a California resident and wish to seek to exercise these rights, please reach us in one of the following ways:

      For more information regarding this Privacy Policy, or if you have any questions or concerns, you may contact us in the following ways:

      Please consult the other sections of our Privacy Policy for further information on our practices regarding your personal information.

      Shine the Light Law

      Under California’s “Shine the Light” law, California residents who provide personal information in obtaining products or services for
      personal, family or household use may be entitled to request and obtain from us, once per calendar year, information about customer
      information we have shared, if any, with other businesses for such other businesses’ own direct marketing uses. If applicable, this
      information would include the categories of resident information and the names and addresses of those businesses with which we shared such
      resident information for the immediately prior calendar year. To obtain this information, please contact us as indicated below. Please include
      sufficient personal identification information so that we can process the request, including that you are a California resident.