Privacy Policy

1. Scope

This Privacy Policy explains how CourtesyCar.ca, operated by Panda Industries (“CourtesyCar,” “we,” “us,” or “our”), handles personal information in connection with our website, administration portal, progressive web application and related services.

This Policy applies to account owners, administrators, staff users, prospective customers, website visitors, and individuals whose information is processed through an organization’s CourtesyCar account, such as drivers or vehicle borrowers.

It does not replace the privacy policy or legal obligations of the dealership, repair facility, collision centre or other organization using CourtesyCar (the “Customer Organization”). Customer Organizations remain responsible for their own collection, use and disclosure decisions.

2. Privacy laws and accountability

We aim to handle personal information in accordance with applicable Canadian private-sector privacy law. Depending on the circumstances, this may include the federal Personal Information Protection and Electronic Documents Act (PIPEDA) and substantially similar provincial private-sector privacy laws, including Alberta’s Personal Information Protection Act (PIPA).

CourtesyCar designates responsibility for privacy compliance to its Privacy Officer. Questions, access requests and complaints can be sent to the contact information at the end of this Policy.

3. Our role and the Customer Organization’s role

For business account information, billing information, website usage and direct communications with us, CourtesyCar determines the purposes for which that information is processed.

For driver, customer, vehicle-handoff and inspection information entered by a Customer Organization, the Customer Organization generally determines why the information is collected and how it will be used. CourtesyCar processes that information on the Customer Organization’s instructions to provide the Service, subject to our own legal and security obligations.

If you are a driver or customer of a business using CourtesyCar, you may need to contact that business first to exercise rights relating to a specific agreement or vehicle transaction. We will assist Customer Organizations with legitimate requests where appropriate.

4. Information we collect

Business and account information

• business or organization name;
• contact name, email address and telephone number;
• account role, status and login activity;
• organization address, branding, logo and operational settings;
• subscription plan, fleet allowance, billing status and Stripe customer/subscription identifiers; and
• support communications and administrative audit events.

Driver and customer information

Depending on how a Customer Organization configures and uses CourtesyCar, records may include:

• name, email address, telephone number and mailing address;
• date of birth;
• driver-licence number or a protected representation of the licence number;
• issuing province, licence class, conditions and expiry date;
• agreement and vehicle-use information;
• electronic signatures;
• customer notes and communications; and
• other information deliberately entered by authorized staff.

Vehicle, inspection and evidence information

• VIN, unit number, make, model, year, trim and fuel type;
• odometer and fuel readings;
• checkout and return dates and times;
• condition photographs, observations and damage reports;
• repair and vehicle-readiness records;
• staff member responsible for checkout, return, inspection or review;
• file integrity information such as hashes, dimensions and timestamps; and
• PDF agreements and return confirmations.

Technical information

We may process IP address, browser and device information, session identifiers, security logs, error logs, request timing information and other technical data needed to authenticate users, secure the Service, diagnose failures and maintain reliable operation.

5. Driver-licence photographs

CourtesyCar is designed to minimize retention of driver-licence images. When the licence-scanning feature is used, the image is transmitted for automated extraction and is intended to be discarded after processing rather than retained as a normal Customer Organization record or inspection image.

The structured information extracted from the licence may be stored after authorized staff review and confirmation. Automated extraction can make mistakes, and staff are required to verify the returned data.

6. Why we use personal information

We may use personal information for reasonable purposes including:

• creating, verifying and administering CourtesyCar accounts;
• providing vehicle checkout, return, inspection, signature and reporting workflows;
• generating and delivering agreements, return confirmations and other records;
• maintaining vehicle and customer history;
• processing subscriptions, fleet allowances and payments;
• protecting the integrity of evidence and maintaining audit trails;
• authenticating users and preventing unauthorized access, fraud and abuse;
• providing support, troubleshooting and communicating service notices;
• monitoring reliability, performance and security;
• complying with legal obligations and responding to lawful requests; and
• improving the Service using aggregated, de-identified or appropriately protected information.

We do not sell personal information.

7. Consent and lawful authority

Where CourtesyCar collects personal information directly from you, we seek consent or rely on another lawful basis where permitted. Where a Customer Organization enters information about its drivers or customers, that organization is responsible for providing required notices and obtaining required consent or other lawful authority.

We and our Customer Organizations should collect only information that is reasonably necessary for legitimate purposes. CourtesyCar should not be used to collect unrelated sensitive information simply because the system permits free-form notes or image capture.

8. Service providers and disclosures

We use service providers to operate CourtesyCar. Depending on the feature used, personal information may be processed by providers such as:

• Stripe for payment processing, subscription management and billing portals;
• Cloudflare R2 for protected object storage of vehicle photographs and generated records;
• OpenAI or another document-processing provider for driver-licence data extraction when that feature is used;
• Resend or another email delivery provider for verification emails, agreements, return confirmations and service messages;
• infrastructure and hosting providers for application and database hosting, networking, backup and security; and
• professional advisers or contractors who require limited access to support the business and are subject to appropriate obligations.

We may also disclose information where required by law, court order or lawful government request; to investigate fraud or security incidents; to protect legal rights and safety; or in connection with a corporate transaction such as a sale, merger or reorganization, subject to appropriate confidentiality and legal requirements.

9. Processing outside Canada

Some service providers may process or store information outside Alberta or outside Canada. Information handled in another jurisdiction may be subject to the laws of that jurisdiction and may be accessible to courts, law-enforcement or government authorities in accordance with those laws.

Where personal information is transferred to a service provider for processing, we remain accountable for selecting and managing providers appropriate to the nature of the information and the service being performed.

10. Payments

CourtesyCar does not need to store complete payment-card details. Payment information is collected and processed by Stripe or the payment provider shown at checkout. We receive identifiers and billing information needed to administer the subscription, such as customer ID, subscription ID, plan, status, renewal information and permitted fleet quantity.

11. Cookies, sessions and local storage

CourtesyCar uses essential browser technologies such as cookies, server-side sessions and local storage to keep users signed in, protect forms, maintain security state, support progressive-web-app functionality and remember limited interface state.

We do not currently rely on these technologies for third-party behavioural advertising. If we introduce non-essential analytics or advertising technologies, we will update this Policy and implement any consent mechanisms required by applicable law.

12. Security safeguards

We use administrative, technical and organizational safeguards appropriate to the sensitivity of the information we process. Depending on the data and feature, safeguards may include access controls, organization-level data separation, password hashing, encrypted transport, protected object storage, protected or hashed licence identifiers, audit logging, evidence-integrity hashes, role-based access, retention controls, session protection and restricted administrative access.

No internet service can guarantee absolute security. Customers are responsible for securing their own devices, passwords, staff accounts, networks and internal business processes.

13. Retention

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, Customer Organization instructions, security and dispute needs, and applicable legal obligations.

CourtesyCar supports configurable retention for certain clean agreement and inspection records. Some records may be retained longer where there is reported damage, a legal hold, an unresolved dispute, a security investigation, an outstanding payment issue or another legitimate requirement.

Account, billing, audit and security records may have different retention periods from vehicle photographs. Backup copies may persist for a limited period after primary records are deleted until normal backup rotation completes.

14. Data accuracy

Customer Organizations and authorized users can update many records directly. Because driver-licence extraction and other data entry can contain errors, users should review important information before relying on it. We may correct information when a legitimate correction request is verified.

15. Access and correction

Subject to applicable law, individuals may have rights to request access to personal information about them and to request correction of inaccurate information. Requests can be sent to our Privacy Officer.

If the information is controlled by a Customer Organization, we may refer the request to that organization or coordinate with it. We may need to verify identity before providing access. Legal exceptions may permit or require us to withhold certain information.

16. Deletion and account closure

A request to delete information does not necessarily require immediate deletion of every record. CourtesyCar or a Customer Organization may need to preserve records required by law, reasonably necessary for a dispute, subject to legal hold, required for fraud/security prevention, or necessary to complete an active transaction.

When information is no longer required, it may be securely deleted, anonymized or de-identified in accordance with applicable requirements and operational backup cycles.

17. Privacy breaches

We maintain procedures to investigate suspected privacy and security incidents. Where applicable law requires notification or reporting, we will assess the circumstances and take required steps. Customer Organizations remain responsible for breach obligations that apply to information under their control, and we will reasonably cooperate where an incident involving CourtesyCar affects their data.

18. Email and commercial communications

We send transactional messages necessary to provide the Service, such as account verification, security notices, agreements, return confirmations, invoices and service communications.

Where we send marketing or other commercial electronic messages, we will seek or rely on consent as required by Canada’s anti-spam legislation (CASL) and provide an appropriate unsubscribe mechanism. Unsubscribing from marketing does not prevent necessary transactional or security messages.

19. Children

CourtesyCar is a business service and is not directed to children. Account users must be adults authorized by a Customer Organization. Customer Organizations should not use CourtesyCar to collect information about minors unless they have a legitimate, lawful need and all required authority to do so.

20. Changes to this Policy

We may update this Policy as the Service, providers or legal requirements change. The effective date and version appear at the top. Material changes will be communicated through the Service, email or another reasonable method where appropriate.

21. Questions, requests and complaints

Privacy questions, access/correction requests and complaints may be directed to:

We will investigate privacy complaints in good faith and respond within a reasonable period. You may also have the right to contact the privacy regulator with jurisdiction over the matter.