Our Commitment To You
At MANIFOLD AUTOS (the “Company”, “we”, “us”, “our”), the privacy of its users, consumers, clients, service providers, distributors, retailers, suppliers and other individuals (“you”, “your”) is a top priority. Your privacy is at the core of the way we design and build the services and products we provide to you. We appreciate that you put your trust in us when you provide us with your personal information and we do not take this lightly.
We do not compromise with your privacy. We design all of our products and services with your privacy in mind. We strive to be transparent in the way we process your data. We work hard to keep your information secure. We have teams dedicated to keeping your data safe and secure. We constantly update our security practices and invest in our security efforts to enhance the safety of your personal information.
Privacy Policy
This Privacy Policy sets out the privacy policies and practices for the Company with respect to how the Company collects your personal information. It also describes how the Company uses, maintains, retains, transfers and discloses your personal information.
This Privacy Policy applies to information collected from you by the Company via https://portal.manifold.autos, https://www.manifold.autos, our online forms, our intake forms, our software, our products and our mobile application (collectively, the “Platform”) and other places where, or means by which, we may collect personal information.
This Privacy Policy also sets out how you can access certain information that the Company may collect about you and explains the choices you have regarding any collection, use, maintenance, retention, transfer and disclosure of such information, and how you may access or correct that information.
In this Privacy Policy, “personal information” means any information about an identifiable individual or information that allows an individual to be identified, as defined from time to time in applicable privacy legislation. Personal information does not include business contact information such as your name, title or position, business address, telephone number, facsimile number or e-mail address.
Terms
In this Privacy Policy the following term has the following meaning:
Insurer(s): any and all auto insurance brokers, agents, carriers and coverage providers for vehicles equipped with, using or being monitored by our technology, devices, software and or hardware.
Your Consent
By submitting personal information to us, you agree that we may collect, use, maintain, retain, transfer and disclose such personal information in accordance with this Privacy Policy and as permitted or required by law. Subject to legal, logistics and contractual requirements, you may refuse or withdraw your consent at any time by contacting the Company’s Privacy Officer at the address provided below. If you refuse or withdraw your consent, you acknowledge that we may not be able to provide you, or continue to provide you, with certain services, products or information. You are responsible for ensuring the accuracy of the personal information that you submit to us. Inaccurate information will affect your experience when using the Platform and our ability to contact you, serve you and meet any obligations we may have to you as described in this Privacy Policy.
Amendments Of This Privacy Policy
We may change, modify, add or remove portions of this Privacy Policy at any time and from time to time, without prior notice to you. We will treat your continued use of the Platform following such change, modification, addition or removal as your acceptance of such revisions. All revisions will be posted on the Platform and will apply to any personal information collected on or after the date posted. We will obtain the necessary consents required under applicable privacy laws if we seek to collect, use, maintain, retain, transfer or disclose your personal information for purposes other than those to which consent has been obtained unless otherwise required or permitted by law.
Collection Of Your Personal Information
We are the controller and the responsible party for your personal information. We may collect personal information in connection with your use of the Platform or with your use or purchase of the Company’s products and services, which may include personal information provided in connection with your use of the Platform.
When you use our Platform, we collect information about which features you have used, how you have used them and the devices you use to access our Platform as well as information about your vehicle. The personal information that we may collect may include:
(a) Information you provide to us when you are:
(i) Registering for an account. You provide us with your name, email address, zip or postal code, billing address, residential address, shipping address, phone number, payment card information, vehicle license and registration information, company information, product preferences, demographic information, your driver’s license, your habits relating to use of any drugs, alcohol, tobacco and any other personal information you choose to provide. By choosing to provide this information, you consent to our processing of that information. If you provide a mobile number, it will be used to deliver program related SMS messages you have opted into and will not be shared with third parties or affiliates for marketing or promotional purposes.
(ii) Participating in surveys or focus groups. You give us your insights into our products and services, responses to our questions and testimonials.
(iii) Registering or filling in forms on the Platform.
(iv) Purchasing any product or service from the Company and or when you subscribe to a paid service or make a purchase directly from us rather than through a third party platform. You provide us or our payment service provider with information such as your credit card and debit card numbers with expiration dates and CVV or other financial information. We use Transport Layer Security encryption technology to encrypt sensitive personal information such as your payment information before it travels over the internet. Credit card numbers are never stored on our database or servers. We use third party providers to process any payments made by you and such third party providers may store your personal information on their databases and or servers.
(v) Reviewing any product or service from the Company.
(vi) Participating in our promotions, events or contests and in such instances, we collect the information that you use to register or enter.
(vii) Requesting for us to communicate with or otherwise process information of other people. In such instances, we collect the information about others that you give us in order to complete your request. If you provide us with personal information of another individual, you represent to us that you have that individual’s consent to allow us to collect, use, maintain, retain, transfer and disclose that personal information in accordance with this Privacy Policy.
(viii) Requesting information or assistance from the Company. This includes information you may provide when you request additional information about the Company’s products and services or sign up to receive the Company’s email newsletters or coupons. The Company may also keep a copy of any communications or correspondence you may send to it, including any email communications.
(ix) Using other features, including interactive functions of the Platform that may be offered from time to time, and may require such information in order to utilize the feature.
(b) Information others provide to us about you. We will apply this Privacy Policy to any personal information received from third parties, unless we have disclosed otherwise. In addition to the information you provide to us directly, we may receive information about you from other parties. For example:
(i) Other users may provide information about you as they use our products and services. We may also collect information about you from other users if they contact us about you.
(ii) We may receive personal information about you from our affiliates or service providers. We may supplement the information we collect about you through the Platform with records received from third parties in order to enhance our ability to serve you, to tailor our content to you, and to offer you information that we believe may be of interest to you. For example, advertising networks may tell us which ads about the Company you clicked on.
(c) Information collected when you use the Platform. When you use our Platform, we collect information about which features you have used, how you have used them and the devices you used to access our Platform. For instance, we collect information:
(i) About your activity on our Platform such as date and time you logged in, features you have been using, searches, clicks and pages which have been shown to you, referring webpage address and advertising that you click on.
(ii) About the device or devices you use to access our Platform including:
• hardware and software information such as manufacturer, model, IP address, device identification and type, operating system and identifiers associated with cookies or other technologies that may uniquely identify your device or browser such as IMEI or UDID and MAC address
• information on your wireless and mobile network connection such as your service provider and signal strength and information on device sensors such as accelerometers, gyroscopes and compasses
(iii) From the device or devices you use to access our Platform including your:
• address book and contacts saved to your device
• device specific and application settings and characteristics, application crashes, advertising IDs such as Google AAID and Apple IDFA, browser type, version and language, time zones
(iv) Other information such as:
• machine data, sensory data, spatiotemporal data, real time data and high dimensional data captured by hardware and or devices distributed, leased and or sold by us
• your vehicle make, model, manufacturer, year of manufacture, vehicle identification number and vehicle color
• your precise geolocation latitude and longitude through various means, depending on the service, vehicle and device you are using, including GPS, magnetic field sensors, Bluetooth or Wi Fi connections. The collection of your geolocation may occur in the background even when you are not using the Platform
• your vehicle operating habits, driving style, use of cell phone or other dangerous activity
• risk or safety data from your vehicle
• frequency and duration of vehicle use
• data from your inputs into your vehicle and messages within the vehicle’s internal messaging and communication systems
• audio and video recordings of you and your vehicle inside and outside of the vehicle
• your photos, images and videos
• any other personal information that you choose to include in your account, while using the Platform or in other communications to the Company
We may collect personal information even when you are not using the Platform. We may combine personal and non personal information about you collected by us or by our affiliates, retailers, distributors and other third parties including Insurers with whom we have a relationship, and we may combine this information with information from external sources.
In obtaining your consent to collect, use, maintain, retain, transfer and disclose your personal information we will use reasonable efforts to inform you of the purpose for which personal information will be collected, used, maintained, retained, transferred or disclosed. The form of consent may vary depending on the circumstances and type of information disclosed. We will take into account the sensitivity of the personal information and your reasonable expectations when determining the appropriate form of consent.
Communications
You may voluntarily submit personal information to us for purposes such as asking a question, obtaining information, reviewing or downloading a publication, registering for an account, purchasing a product or service, reviewing a product or service provided by the Company, engaging in coaching and training messages and or events, subscribing to a newsletter or a mail or email list and participating in contests and surveys. If you are a user of the Platform, we may combine and store personal information about your use of the Platform and information you have provided to us with certain other online and offline information we may have collected.
Mobile Information Policy
We respect the privacy of your mobile information.
• We do not share, sell, rent or disclose any mobile numbers or mobile information with third parties or affiliates for marketing or promotional purposes.
• Mobile information collected for messaging purposes such as phone numbers, opt in status and message preferences is used exclusively to send program related messages and notifications as described in this Privacy Policy.
• Mobile information may be shared only with service providers that enable messaging delivery or as required by law. It is not added to marketing lists, nor sold or shared for advertising.
E mail Communications
We may send you marketing or promotional email communications. In this process, we may collect certain information such as the date and time you first opened our email communications, the number of times you open our email communications, the number of instances you click through our articles and your total click through activity on the contents of our email communications. We may also combine and store any such information to manage and improve our email communications. If you no longer wish to receive any future marketing or promotional material from us, our promotional email communications will include instructions on how to unsubscribe and inform us of your preferences.
SMS And Text Messaging
By providing your mobile number and opting in, you agree to receive text messages from Manifold Autos related to account notifications, product or service updates and program information. Message and data rates may apply. Message frequency varies. Reply STOP to opt out. Reply HELP for help. Mobile information is used only to deliver these messages and is not shared with third parties or affiliates for marketing or promotional purposes.
Cookies
We aim to provide a secure Platform and to improve our Platform for you, including by remembering your preferences, recognizing you when you visit our Platform and personalizing and tailoring ads to your interests. To accomplish these purposes, we may use a browser feature called a cookie to collect information when you access the Platform. A cookie is a small text file containing a unique identification number that identifies your browser, but not necessarily you, to our computers each time you visit the Platform.
We may use such personal information and share it with third parties with whom we have a commercial relationship to measure the use of the Platform, to improve the functionality and content of the Platform and to simplify your usage of the Platform.
We also use similar technologies for example web beacons also known as tracking pixels, Meta Pixel and cookies that other third party ad networks use, that enable us to recognise when someone has used our Platform or opened an email that we have sent them.
There are different types of cookies including first party cookies, third party cookies, session cookies and persistent cookies. When you use our Platform, some or all of the following types of cookies may be set on your device: essential website cookies, analytics cookies, advertising cookies and social networking cookies.
Unless you specifically inform us, we will not know who you are. You can reset your browser either to notify you when you receive a cookie or refuse to accept cookies. If you refuse to accept cookies, you may not be able to use some of the features available on the Platform.
You may control cookie settings in your browser and device. With respect to interest based advertising tools, you may opt out of seeing online interest based advertising from participating companies by using the Digital Advertising Alliance, the Interactive Digital Advertising Alliance, or AppChoices. Opting out does not mean you will not see any advertisements. If you delete cookies after you opted out, you will need to opt out again.
Third Party Websites
We may include links to other websites on the Platform or in our communications. These third party websites may collect your personal information and they may have different privacy policies and practices than us. We do not assume any responsibility for the privacy practices, policies or actions of the third parties operating these third party websites. We strongly encourage you to read the privacy policies of these websites.
Disclosure Of Your Personal Information
We may disclose your personal information to authorized partners such as Insurers and service providers solely for operational purposes related to the services we provide. We do not sell or share mobile numbers or mobile information with third parties or affiliates for marketing or promotional purposes.
Occasionally, we may disclose your personal information to:
(a) Third party service providers or vendors such as organizations retained by us to collect outstanding debts, our financial institution, distributors and retailers.
(b) A person who, in our reasonable judgment, is providing or seeking the information as your agent.
(c) Insurers.
(d) Your employer and or fleet manager.
(e) Our personnel or contractors.
(f) Government authorities, regulatory agencies, insurers, benefits providers, consultants or agents.
(g) Any third party or parties where you consent to such disclosure or where disclosure is required or permitted by law.
You hereby acknowledge and agree that we may disclose your personal information and your overall driving behavior and patterns and our evaluation of same to your Insurer. You hereby further acknowledge and agree that such disclosure may cause an increase in your insurance premium and may affect your qualification for certain rates, products and or services offered by your Insurer.
You hereby acknowledge and agree that we may disclose your personal information and your overall driving behavior and patterns and our evaluation of same to your employer and or fleet manager. You hereby further acknowledge and agree that such disclosure may affect your employment relationship, qualifications, employment position and or salary.
In certain situations, we may use, maintain, retain, transfer or disclose your personal information without your knowledge or consent as permitted or required by law. Such situations may be:
(a) Where your personal information is publicly available.
(b) Where collection or use of the personal information is unmistakably in your interests and consent cannot be obtained in a timely manner.
(c) To investigate a breach of an agreement or a contravention of law.
(d) In the event of a corporate change in control of the Company resulting from for example a merger, a reorganization, a sale of assets or bankruptcy.
(e) To comply with a subpoena, warrant, court order or as required or otherwise permitted by law.
(f) When information is being collected for the detection and prevention of fraud or for law enforcement.
Third Party Analytics
To evaluate the usage of the Platform, we use automated devices and applications provided by third parties, such as Google Analytics. We use these tools to help us improve our products and services, our performance and user experiences. These entities may use cookies and other tracking technologies which collect information to perform their services and may collect personal information directly through the use of cookies and other tracking technologies. If you wish to opt out of Google Analytics data collection, please use the Google Analytics Opt Out Browser Add On.
IP Addresses
An IP address is a device’s numeric address, by which it can be located within a network. We may record your IP address when you visit the Platform. We may use your IP address to help diagnose problems with the Company’s server, administer the Platform, identify you when we believe it is necessary to enforce compliance with this Privacy Policy or the Terms and Conditions, or protect the Platform and our systems, information, employees, service providers, business partners, affiliates, users, customers, distributors, retailers and others.
Protection Of Your Personal Information
To prevent unauthorized access to, or disclosure of, personal information, maintain data accuracy and facilitate the appropriate use of your personal information, we use physical, technological and administrative procedures to protect your personal information that we collect from loss, unauthorized access, modification, unauthorized disclosure or other misuse. Nevertheless, internet or wireless transmissions are never completely private or secure.
Use Of Your Personal Information
Once we collect your personal information, we may use such personal information internally, separately or in combination with any pre existing information for the following purposes:
(a) To provide our products and services to you, including:
(i) To administer your account.
(ii) To assist with billing and the collection of accounts.
(iii) To provide you with transaction receipts.
(iv) To process and fulfill your order, including to send you emails to confirm your order status and other related emails.
(v) To develop, enhance, market, sell or otherwise provide information, products or services.
(vi) To contact you and to respond to any communications that you may have had with us.
(vii) To conduct or administer contests, sweepstakes or other promotions in which you have participated.
(viii) To distribute our newsletters and other informational communications and other material to individuals on our mail, SMS and email lists.
(b) To ensure consistent experience with our Platform across all of your devices, including:
(i) To troubleshoot problems with the Platform.
(ii) To customize your experience or homepage on the Platform.
(iii) To obtain your feedback on the Platform, our products and services.
(iv) To establish and conduct commercial relationships, including to process transactions and to conduct or administer other transactions that you may engage in with us.
(c) To evaluate your driving behaviour and patterns and the safety of your vehicle and its passengers.
(d) To improve our products and services and to develop new products and services, including:
(i) To evaluate our service providers and their qualifications.
(ii) To help us learn more about your preferences.
(iii) To conduct surveys, research, evaluations and measurement activities.
(e) To prevent, detect and fight fraud or other illegal or unauthorized activities, including:
(i) To detect, and to protect the Company and other third parties against, error, negligence, breach of contract, fraud, theft and other illegal activity.
(ii) To audit compliance with our policies and contractual obligations.
(f) To ensure legal compliance, including:
(i) To enforce our Terms and Conditions and this Privacy Policy.
(ii) As permitted by, and to comply with, any legal or regulatory requirements or provisions.
(iii) To use, maintain, retain, transfer and disclose your personal information if the Company is required to do so by law or legal process or if the Company determines that such action is necessary to protect the rights of the Company, third parties and other users of the Platform or to respond to your request for customer service.
(g) For our business purposes, including:
(i) To engage in business transactions, including the purchase, sale, lease, merger, amalgamation or any other type of acquisition, disposal, securitization or financing involving the Company.
(ii) To market, sell or otherwise provide products and services of third parties with whom we have a commercial relationship.
(h) To provide information about your driving habits, risky behavior and driving incidents to you, your employer and or fleet manager, Insurers, law enforcement and other third parties.
(i) To coach you towards safer driving and to improve the safety of the roads.
(j) To develop and manage our business and operations.
(k) For any other purpose to which you consent.
For clarity, mobile numbers and mobile information are used only to deliver opted in messaging and are not shared with third parties or affiliates for marketing or promotional purposes.
To process your information as described above, we rely on the following legal bases:
(a) The primary reason we process your personal information is to perform the contract that you have with us for example to maintain your account.
(b) We may use your personal information where we have legitimate interests to do so for example to improve our products and services by analyzing users’ behavior on our Platform and for administrative, fraud detection and other legal purposes.
(c) We may occasionally ask for your consent to use your personal information for certain specific reasons. You may withdraw your consent at any time by contacting us.
Retention Of Your Personal Information
After we have collected your personal information, we may retain a record of your personal information including correspondence or comments. We will continue to use, maintain, transfer, disclose or retain your personal information for as long as necessary to fulfill the purposes for which it was collected and as required or permitted by law. However, we will take reasonable steps to destroy or permanently de identify personal information we hold if it is no longer needed for our business purposes.
Cross Border Data Transfers
Sharing your personal information sometimes involves cross border data transfers, for instance to the United States of America and other jurisdictions. To increase our efficiency, we use password protected electronic file storage on cloud servers based outside of Canada, in countries where laws regarding collection, use, maintenance, transfer and disclosure of personal information may be less stringent than the laws in Canada.
Control Of, Access To, And Correction Of, Your Personal Information
If you do not want your personal information collected, used, maintained, transferred, disclosed or retained by us as provided in this Privacy Policy, you should not use the Platform and you should refrain from registering for any specific tool or application that collects personal information and from purchasing any product or service from us.
You may uninstall the Platform from your device using the standard uninstall process for your device. If you uninstall the Platform from your device, the unique identifier associated with your device will continue to be stored by us. If you re install the Platform on the same device, we will be able to re associate this identifier to your previous transactions and activities.
You may also use tools and account settings that help you to access, rectify or delete information that you provided to us and that is associated with your account directly within the Platform. Devices have permission systems for specific types of device data and notifications, such as address book and location services as well as push notifications. You can change your settings on your device to either consent or oppose the collection of the corresponding information or the display of the corresponding notifications. Changing such device settings may result in your loss of full functionality of the Platform.
You may request a copy of the personal information which you have provided to us by advising our Company’s Privacy Officer at the address provided below. If you have any questions or enquiries relating to our privacy practices or procedures, or if you believe that the personal information that the Company holds about you is not accurate, complete or up to date, you may write to the Company’s Privacy Officer. If you are able to establish that the information is not accurate, complete or up to date, we will take reasonable steps to correct the information so that it is accurate, complete and up to date. We may ask you to provide proof of identity before we can answer the above requests.
Non Canadian Users
If you are located outside of Canada, please note that the information you provide to us will be used, maintained, retained, transferred and disclosed in Canada, where laws regarding use of personal information may be less stringent than the laws in your country. By using our Platform, you consent to such use, maintenance, retention, transfer and disclosure. You also consent to the adjudication of any disputes arising in connection with the Platform, this Privacy Policy and the Terms and Conditions in the Federal Court of Canada and the courts of the Province of Ontario.
Questions Or Comments
We welcome questions and comments about this Privacy Policy. If you wish to access, verify and or amend your personal information or make a complaint under this Privacy Policy, please contact the Company’s Privacy Officer at support@manifold.autos