PRIVACY POLICY

Finloc 2000 Inc. (the “Company” or “we”) values its customers, respects their privacy and recognizes that it must maintain and use their personal information responsibly. We have created this privacy policy (the “Policy”) to demonstrate our firm commitment to your privacy and security, and to advise you about the collection, use and disclosure of personal information and how we collect and use personal information to provide our services (the “Services”). This policy applies to all users of our apps, website interfaces and features (collectively, “vHub”). The Policy also provides you with the ability to “opt‑out” of providing personal information that you do not wish to provide and to access, change or remove any personal information already collected. The Company will not collect, use or disclose your personal information other than in compliance with the Policy.

By providing any personal information by using the Services and/or by accessing and using vHub or the Company microsites, you thereby agree to all of the terms and conditions of the Policy and consent to the collection, use and disclosure of your personal information as described in the Policy. You are responsible to ensure that your access to vHub and material available on or through it is legal in each jurisdiction in or through which you access or view vHub or such material.

The terms “we”, “us”, and “our” used in the Policy refer, collectively, to the Company and its affiliates, divisions, successors and assigns and their respective employees, mandataries and agents (collectively, the “Company Affiliates”).

1. WHAT INFORMATION IS COLLECTED BY THE COMPANY?

Any time you use our Services or introduce any information, content or other materials through vHub or otherwise provide personal information to the Company (including via mail or e‑mail in regular correspondence), it may be collected, used and disclosed by the Company for various purposes as described herein.

Information created when you use our Services:

  • Device Information: Every time you visit or use vHub, the following information is automatically obtained and compiled: your internet protocol (IP) address and the domain name registry information associated with that IP address; identification of your internet browser, operating system and/or hardware you are using; the date and time of your visit; the name and address (URL) of the web page you viewed immediately prior to accessing vHub; your entire query (if any) that was entered into a search engine which led you to vHub; and any other “click stream” data. This information is stored in our log files. Occasionally, if your browser is not configured to prevent disclosure of such information, the following information may also be revealed to us: your name, e‑mail address, home and work addresses, telephone and fax numbers and any plain text commentary.
  • Usage Information: The complete record of your actions on vHub, including without limitation access dates and times, app features or pages viewed, the time spent on each page, the information sent or received and the names of all files uploaded or downloaded is collected.
  • Geolocation Information: Depending on the Services that you use, your device settings and device permissions, we may collect your precise or approximate location information as determined through data such as GPS, IP address and WiFi. This information may include:
    • Geolocation information when vHub is running in the foreground (app open and on-screen) or background (app open but not on screen) of your device.
    • If you have not restricted permission for the processing of location data, we collect location information when vHub is running in the foreground or information provided from other geolocation devices in your vehicle while using the Services. You hereby represent and warrant to the Company that you have all required third-party consents and authorizations to provide such geolocation data to us for our collection and use.
    • You may use vHub without enabling us to collect your geolocation data. However, this may affect or restrict the functionalities available on vHub.
  • Transaction Information: We collect transaction details related to your use of our Services and navigation on vHub, including the types and frequency of services you requested or provided, your transaction details, date and time the Services were used, amounts charged or transferred, distances traveled, routes considered and taken for transit, requests made, as well as payment methods.
  • Communications Data: We enable users to communicate with each other and us through vHub. For example, we enable renters and owners to call or text each other. To provide this Service, the Company receives some information regarding the calls or texts, including the date and time of the call/text, and the content of the communications. Renters and owners may also exchange contact information and communicate directly outside of vHub. The Company may also, but is not obligated to, use this information to improve our products and services and for analytics.

Information you provide:

  • User profile: We collect information when you create, edit or update your vHub account. Such information shall namely include, as the case may be, your name, email, phone number, login name and password, address, payment information (including related payment verification information), licenses, your pictures including those of physical persons, movables or things, restrictions or instructions regarding assets provided to users through vHub, government identification numbers such as driver’s license, birth date, photo and signature. This also includes equipment or insurance information and certificates. This also includes the preferences and settings that you enable for your vHub account(s).
  • Demographic data: We may collect demographic information about you, including through user surveys.
  • User content: We may collect information that you submit when you provide ratings, comments and feedback to others through vHub or otherwise contact us.

In light of the importance of protecting children’s privacy, we do not intend vHub for child audiences, and we do not collect, process or use on vHub any information relating to an individual whom we know to be under 13 years old without the prior, verifiable consent of his or her parent or other legal representative. If a parent or guardian discovers that his or her child has provided us with personally identifiable information, such parent or guardian has the right, upon request, to view the information provided by the child and/or to require that it be deleted from our records. In such a case we ask that the parent or guardian of the child contact us at the contact information provided in the “Contacting Us” section below for such purpose.

2. HOW IS YOUR PERSONAL INFORMATION USED?

In order to better serve you as well as maintain and improve our product and service offering, we may combine and aggregate information we collect directly or indirectly from you through vHub or your use of the Services. We may also combine these with readily available demographic or geographic information in order to enable us to communicate with you, by telephone (including by way of automated dialing answering device), e‑mail, mail, text, sms or otherwise. We also collect this information in order to:

  • Develop, Offer and Provide Services and Features: vHub uses the information it collects to develop, offer, provide, personalize, maintain and improve vHub products and services. This includes using the information to:
    • Create and update your account.
    • Verify your identity.
    • Processing of your information.
    • Process or facilitate payments for Services.
    • To track the progress of your rental.
    • Create and enable features that allow you to share information with other people, such as when you submit a rating about a renter or owner.
    • Create and enable features to personalize your vHub account.
    • Perform internal operations necessary to provide our services and develop new products, including to troubleshoot software bugs and operational problems, to conduct data analysis, testing, and research, and to monitor and analyze usage and activity trends.
    • Develop new products, services and offerings.
  • Research and Development: We may use the information we collect for testing, research, analysis and product development. This allows us to improve and enhance the efficiency and quality of our Services, develop new features and products, and facilitate insurance and finance solutions in connection with our Services.
  • Communications Among Users: We use the information we collect to enable communications between our users. For example, a driver may text or call an owner.
  • Communications from Us: We may use the information we collect to communicate with you about products, services, promotions, studies, surveys, news, updates and events.
  • Legal Proceedings and Requirements: We may use the information we collect to investigate or address claims or disputes relating to your use of the Services, to investigate any actual or threatened security breach of vHub, or as otherwise allowed by applicable law, or as requested by regulators, government entities, and official inquiries.

We may also use information collected from vHub to measure interest in the various areas of vHub, to ensure that links on vHub facilitate easy navigation and to help make vHub more interesting and user friendly. Except as described in the Policy, any personal information that we disclose to third parties is done in the aggregate on a non‑personally identifiable basis and is used primarily to identify demographic and geographic data regarding our customers. You hereby consent to the disclosure of the aggregated data without any compensation to you.

You acknowledge and agree that the Company shall also have the right to incorporate, use and reproduce any text, image, video, audio, or any information, content or other materials you provide through vHub, in whole or in part, in connection with the operation, marketing and promotion of the Company’s business. You always have the right to revoke such consent in the manner described in the section “How do I exercise my choices about the collection, use and disclosure of my personal information?” below.

3. TO WHOM MAY YOUR PERSONAL INFORMATION BE DISCLOSED?

We will not disclose your personal information to any non‑affiliated third party without your prior consent, other than as provided below:

  • With Other Users: We may share information with other users including personal name and photo, make, model, color, license plate, specifications, location and photos of any equipment added to vHub; ratings provided by other users, for how long you have been using vHub, contact information (depending upon applicable laws) and any other information required to provide the Services.
  • To Company Affiliate: We may disclose your personal information to any of the Company Affiliates, so that it may communicate with you (whether by e‑mail, telephone, text, post or otherwise) and provide you with promotional materials and additional information about its products, services, promotions and special offers that may be of interest to you, or collect and use that information subject to and for other purposes contemplated by the Policy.
  • In a Sale Context: In the event of a sale of all or substantially all of our business or another similar transaction (such as a sale of a division or business unit), we may transfer or disclose your personal information to a purchaser or prospective purchaser, who may collect, use and disclose such information for the purposes of evaluating and/or effecting a proposed transaction or operating and managing the affairs of the acquired business, or for other purposes identified in the Policy.
  • Non-Affiliated Third-Parties: We may provide information to vendors, consultants, marketing partners, research firms, and other service providers or business partners of

vHub. This may include, for example:

    • Payment processors and facilitators.
    • Background check providers.
    • Cloud storage providers.
    • Marketing partners and marketing platform providers.
    • Data analytics providers.
    • Research partners, including those performing surveys or research projects in partnership with the Company or on the Company’s behalf.
    • Vendors that assist the Company to enhance the safety and security of its apps.
    • Consultants, lawyers, accountants and other professional service providers.
  • As Required by Law: We reserve the right to disclose your personal information as required by law, in response to legal or regulatory process and law enforcement requests by government authorities that have asserted a lawful right to access such information, to our legal counsel, or as necessary to protect the property, interests and rights of the Company and any Company Affiliates.

4. HOW DO YOU EXERCISE YOUR CHOICES ABOUT RECEIVING PROMOTIONAL COMMUNICATIONS?

You always have the right to direct us not to share your information with third parties (see “How do I exercise my choices about the collection, use and disclosure of my personal information?” below). With regard to the collection and disclosure of aggregate information however, please note that you will not be able to “opt‑out” as this information simply reflects statistical analysis of various aspects of vHub usage and does not include personally identifiable information.

5. WHAT ARE “COOKIES” AND “WEB BEACONS” AND HOW DOES THE COMPANY USE COOKIES ON VHUB?

Cookies are small data files that a website stores on your computer’s hard drive or in random access memory when you are viewing the website. They keep a record of your preferences, making your subsequent use of vHub more efficient. In certain cases, this information is only kept during the session and is deleted when you close your browser or the app. In other cases, the information is stored on your device and, upon your next visit or of vHub, the cookies are used to recall such information. Cookies may store a variety of information, including a unique user ID that can be used to track the pages of vHub you have visited and the number of times that you view a particular page or other item on vHub, login or registration information, your preferences and your purchase history, where available.

No personal information is transmitted via cookies. Cookies, by themselves, cannot be used to reveal or discover the identity of the individual user; your acceptance of our cookies will not compromise your anonymity while using vHub.

We use cookies in order to improve the experience of users of vHub. Your cookies help us keep track of your interests and, if you are a registered customer, your cookies allow us to recognize you when you return to vHub. If you register on vHub, your cookies also help us to monitor and maintain information about your use of vHub. If you have not registered with us, your cookies may be used in order to monitor and maintain non‑personally identifiable information about your use of vHub.

The use of cookies is a common practice adopted by most major websites and apps to better serve their clients. Most internet browsers are designed to accept cookies, but they can be easily modified to warn you each time a cookie is being sent or to block all cookies. This is done through your browser settings; see your browser’s help files for details on how to block cookies, how to know when you have received cookies and how to disable cookies completely. You should note, however, that without cookies, some of vHub’s functions will not be available, and you will lose some of the benefits of vHub as, amongst other things, we will not recognize you as a past visitor or a registered user.

Composite tracking information generated by cookies may be shared with third parties for the purpose of documenting Site activity, traffic accounting, content analysis and other trends. Statistical information is not linked to any personal information and cannot identify any individual user of vHub.

“Web beacons”, also sometimes called “pixel tags”, are small strings of code placed on a Web page or in an e‑mail message for the purpose of transferring data.

We and the online marketing company or companies that we use to help manage our Internet business and communications employ cookies and Web beacons placed on vHub’s pages to deliver our ads, to measure the effectiveness of our advertising, including our e‑mail promotions, and to learn how visitors use vHub. The ad‑serving technology uses non‑personal information about your visits to vHub and the sites upon which we advertise to serve our ads to you. In the course of delivering our advertisements, a unique third‑party cookie may be placed on your browser. The Web beacons used in conjunction with this third party ad cookie enable our ad server to recognize a browser’s cookie when a browser visits vHub and to learn which banner ads bring visitors to vHub.

6. HOW DO YOU EXERCISE YOUR CHOICES ABOUT THE COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION?

We would like your consent to collect, use and share your personal information for the purposes and in the manner described herein, including in order to contact you and provide you with promotional communications. Nonetheless, we want you to know that you have choices and can refuse or withdraw your consent as described below.

You have the choice simply not to submit any personal information to us, however this may limit our ability to serve you as it may prevent you from using or restrict your use of vHub or the Services. You may also choose only to submit information constituting required fields. In addition, you may choose to limit how we use your personal information by not allowing us to share such information with third parties by e‑mailing us at the contact link below. This may also prevent or restrict your use of vHub and/or the Services.

In the event that you have already consented to the collection, use and/or disclosure of your personal information, you may subsequently “opt‑out” at any time, subject to legal or contractual restrictions and reasonable notice, by contacting our privacy officer as described in the section entitled “Contacting us” below, or by following the “opt‑out” instructions provided in the promotional materials sent to you. Our privacy officer will also be able to provide you with more information regarding the implications of withdrawing consent.

In respect of requests not to receive promotional communications from us, please be sure to include your full name, address, telephone number and any e‑mail address you used when you signed up on vHub or otherwise communicated with us. It may take up to twenty (20) business days to process your request, during which period you may continue to receive communications from the Company or the Company Affiliates. If you prefer not to receive promotional information from the Company or Company Affiliates, please follow the unsubscribe instructions set out in the Policy or in the respective privacy policies and/or communications of the Company Affiliates.

7. HOW CAN YOU ACCESS OR CHANGE YOUR PERSONAL INFORMATION OR MAKE INQUIRIES OR COMPLAINTS IN RELATION TO THE POLICY AND THE COMPANY’S PRIVACY PRACTICES?

You are entitled to request access to, and, if necessary, correct your personal information collected by us. In order to make such a request, please contact our privacy officer in writing (see “Contacting us” below).

THE COMPANY WILL USE ITS COMMERCIALLY REASONABLE EFFORTS TO REMOVE ANY OF YOUR PERSONAL INFORMATION FROM OUR DATABASE WITHIN A REASONABLE PERIOD OF TIME PURSUANT TO A WRITTEN REQUEST FROM YOU. IN THE EVENT SUCH REQUEST IS SENT BY E‑MAIL, PLEASE IDENTIFY YOUR FULL NAME AND PLEASE TYPE “REMOVE PERSONAL INFORMATION” IN THE SUBJECT LINE OF YOUR E‑MAIL.

You can also contact our privacy officer for any questions about or to make any complaint in relation to the Policy, as well as to the Company’s privacy practices in general (see the “Contacting us” section below).

8. HOW LONG IS YOUR PERSONAL INFORMATION RETAINED?

We will keep your personal information only as long as is reasonably necessary for the purposes described in the Policy or such longer period as may be required by applicable law.

9. HOW SECURE IS YOUR PERSONAL INFORMATION?

We take great care in trying to maintain the security of personal information we have collected. We have adopted physical and technological processes and procedures to protect the confidentiality of personal information and to safeguard personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification, in light of, among other things, the sensitivity of the information and the purposes for which it is to be used. Furthermore, each and every Company employee, mandatary or agent must abide by the Policy. Although we do not take responsibility for any theft, misuse, unauthorized disclosure, loss, alteration or destruction of data, we take reasonable precautions to prevent such occurrences.

The Company also strives to offer its customers a secure environment. VHub uses PCI compliant third-party payment processors for all payment processing services and thus all credit card information will be secured in accordance with their own security practices and your payment information and credentials are not stored on our servers. The identity of the third-party payment processing provider will be displayed on the VHub reservation confirmation. VHub reserves the right to change third-party payment processors from time to time without any obligation to provide notice to users.

10. WHILE WE STRIVE TO PROTECT YOUR PERSONAL INFORMATION, WE CANNOT ENSURE OR WARRANT THE SECURITY OF ANY INFORMATION YOU TRANSMIT TO US, AND YOU DO SO AT YOUR OWN RISK.

11. PRIVACY POLICY CHANGES

If we decide to change the Policy, we will post these changes on vHub so that you can be updated as to what information we gather, how that information may be used and whether (and how) it may be disclosed to any third parties. Following the posting of such changes, you will be bound by such changes unless you advise us in writing, by phone or by e‑mail that you wish to withdraw your consent (as per the procedure outlined above). You are responsible for regularly reviewing the Policy and any changes thereto.

12. OTHER WEBSITES

VHUB MAY CONTAIN LINKS TO OTHER WEBSITES THAT ARE NOT OPERATED BY THE COMPANY. THE POLICY DOES NOT APPLY TO THE PRACTICES OF THIRD PARTIES AND THE COMPANY DOES NOT ASSUME ANY RESPONSIBILITY FOR ANY SUCH THIRD PARTY PRACTICES OR FOR THE PRIVACY PRACTICES OF THE WEBSITES THAT IT DOES NOT OPERATE. BY USING VHUB AND/OR ACCESSING A THIRD PARTY’S WEBSITE FROM VHUB, YOU RELEASE THE COMPANY OF ANY RESPONSIBILITY FOR THE ACTIONS, PRACTICES AND OMISSIONS OF THIRD PARTIES. BY CLICKING ON ANY HYPERLINKS TO OTHER WEBSITES FROM VHUB, YOU MAY AUTOMATICALLY SUBMIT TO THE PRIVACY PRACTICES OF THOSE WEBSITES. PLEASE CHECK THE PRIVACY POLICIES OF THESE THIRD PARTY WEBSITES. IN NO EVENT SHALL THE COMPANY OR ANY COMPANY AFFILIATES BE LIABLE TO YOU OR ANYONE ELSE FOR ANY DAMAGES OR INJURY WHATSOEVER (INCLUDING BUT NOT LIMITED TO DIRECT, INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, EXEMPLARY OR PUNITIVE DAMAGES) ARISING OUT OF OR IN CONNECTION WITH THE MISUSE OF PERSONAL INFORMATION BY THOSE WEBSITES.

13. CONTACTING US

The Company has appointed our Corporate Secretary as our Privacy Officer. The Privacy Officer is accountable for the Company’s compliance with the principles of applicable privacy legislation and this Policy.

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 the Company’s care and control, please contact the Privacy Officer at:

BY POST MAIL

11505 1st Avenue
Suite 500
Saint-Georges, Quebec Canada
G5Y 7X3

Attention: Privacy Officer

Last updated: April 11, 2019