Privacy Policy

Last modified: September 1, 2021

1. INTRODUCTION

Tuktu Care Inc. (“Tuktu,” ”we,” “us,” “our,”) respect your privacy and are committed to protecting it by complying with this policy. This policy describes:

• The types of information we may collect or that website or app users (“you”) may provide when you download, install, access, or use www.tuktu.ca (the “Website”) or Tuktu’s mobile application (the “App”, and together with the Website, the “Platform”).
• Our practices for collecting, using, maintaining, protecting, and disclosing that information.

We take steps to ensure that the personal information that we collect about you is adequate, relevant, not excessive, and used for limited purposes. Privacy laws in Canada generally define “personal information” as any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person. Personal information does not include business contact information, including your name, title, or business contact information. This policy applies only to information we collect in the Platform and, in email, text, and other electronic communications sent through or in connection with the Platform. Please read this policy carefully to understand our policies and practices for collecting, processing, and storing your information. If you do not agree with our policies and practices, do not download, register with, or use the Platform. By downloading, registering with, or using the Platform, you indicate that you understand, accept, and consent to the practices described in this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of the Platform after we make changes indicates that you accept and consent to those changes, so please check the policy periodically for updates. If we make material changes to the policy, we will notify you.

2. GEOGRAPHICAL LOCATION OF USERS

We collect information from Users residing in Canada. We do not create User accounts for individuals outside of Canada. You shall not use the Platform from any jurisdiction outside of Canada.

3. INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT

We collect information about you through:

• Direct interactions with you when you provide it to us, for example, by filling in forms, using the Platform, visiting the Site or the App, corresponding with us, or by way of telephone calls with us.
• Automated technologies or interactions, when you use the Platform, for example, usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
• Social media interactions, when you follow our social media platforms, or interact with us on social media.

The types of information that we collect include:

• Personal information that we can reasonably use to directly or indirectly identify you, such as your name, mailing address, email address, telephone number, internet protocol (IP) address, user name or other similar identifier, billing and account information, age, date of birth, gender, demographics, preferences on service providers, and dates and times of service, photographs, and any other identifier we may use to contact you (“personal information”). We provide an opportunity for any user to unsubscribe from our emails or communications or opt-out of contact for marketing purposes on an ongoing basis by accessing the Website, using the unsubscribe mechanism at the bottom of our emails, or emailing to privacy@tuktu.ca.
• Background Information. We also collect background information from you when we run background checks on you before you become a Service Provider (as that term is defined in our Terms and Conditions). For all Users, we collect any and all background information you provide to us, including without limitation, employment history and education.
• Non-personal information that does not directly or indirectly reveal your identity or directly relate to an identified individual, such as demographic information, or statistical or aggregated information. We may derive non-personal statistical or aggregated data from personal information. For example, we may aggregate personal information to calculate the percentage of users accessing a specific app feature.
• Technical information, including your login information, device type, time zone setting, GPS location, and usage details.
• Information and content you provide. We collect the content, communications and other information you provide when you use the Platform, including when you register for an account, create or share content, and message or communicate with others. This can include information in or about the content you provide, such as the location of a photo or the date a file was created. It can also include what you see through features we provide.
• Financial Information. If you choose to share financial information or insurance related information, this information will also be collected by us. You acknowledge and agree that we use a third party payment processor (Stripe) (the "Third Party Payment Processor") to process all payments and financial transactions on our Platform. The Third Party Payment Processor's use of your personal information is governed by their privacy policy which may be viewed at the following web address: www.stripe.com/privacy
• Your networks and connections. We also collect information about the connections you have made with other Users on our Platform.
• Types of services or other transactions while using the Platform. We collect data with respect to your usage of the Platform and the types of services you request from Service Providers. This includes logs and session data when you visit the Platform. We also collect information related to your usage of other sites, what site you came from or what site you visit when you leave our Platform.

Information You Provide to Us When you download, register with, or use the Platform, we may ask you to provide:

• Information by filling in forms in the Platform. This includes information you provide when registering to use the Platform, posting material, or requesting services. We may also ask you for information when you report a problem with the Platform.
• Records and copies of your correspondence, including email addresses and phone numbers, if you contact us.
• Your responses to surveys that we might ask you to complete for research or other purposes.
• Details of transactions you carry out through the Platform and order fulfillment. We may require you to provide financial information before placing an order through the Platform.
• Your search queries on the Platform.

We recommend and encourage you (and all our Users) to think carefully about the information you disclose about yourself. We do not recommend that you disclose your email address, URLs, instant messaging details, phone numbers, full names or addresses, credit card details, national identity numbers, drivers' license details and other sensitive information which is open to abuse and misuse on your profile. When you post information about yourself on your profile or account, the amount of personal information you share is at your own risk. Anonymous Information This is information collected that does not directly or indirectly identify an individual and cannot reasonably be used to identify an individual. We may use or share Anonymous Information without special limitations, including sharing with third parties. Aggregate Information This is information created about groups or categories of individuals from Personal Information and Anonymous Information that does not identify, and cannot reasonably be used to identify, an individual. We may use or share Aggregate Information without special limitations, including sharing with third parties. For example, we may share with a third-party providing research services that, in turn, will help to enhance the experiences of the Tuktu. Such third parties may publish the results of these research findings. You may also provide information for publication or display (“posted”) on public areas of the Platform and other websites you access through the Platform (collectively, “User Contributions”). You post and transmit User Contributions to others at your own risk. Although you may set certain privacy settings for such information by logging into your account profile please be aware that no security measures are perfect. We cannot control the actions of third parties with whom you may choose to share your User Contributions. Therefore, we do not guarantee that unauthorized persons will not view your User Contributions. Automatic Information Collection and Tracking Technologies When you download, access, and use the Platform, it may automatically collect:

• Usage details. When you access and use the Platform, we may automatically collect certain details of your access to and use of the Platform, including traffic data, location data, logs, and other communication data and the resources that you access and use on or through the Platform.
• Device information. We may collect information about your computer, mobile device and internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information, and the device’s telephone number.
• Stored information and files. The Platform also may access metadata and other information associated with other files stored on your device. This may include, for example, photographs, audio and video clips, personal contacts, and address book information.
• Location information. The Platform collects real-time information about the location of your device. All such information is stored with a third party data storage facility which is located in Ohio, United States.

The technologies we use for this automatic data collection may include:

• Cookies (or mobile cookies). A cookie is a small file placed on your smartphone. It may be possible to refuse to accept mobile cookies by activating the appropriate setting on your smartphone. However, if you select this setting you may be unable to access certain parts of our Platform.
• Web beacons. Pages of the Platform and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit Tuktu, for example, to count users who have visited those pages or opened an email and for other related app statistics (for example, recording the popularity of certain app content and verifying system and server integrity).

We may also use these technologies to collect information about your activities over time and across third-party websites, apps or other online services (behavioural tracking). You can opt out of receiving interest-based advertising through the Digital Advertising Alliance of Canada's Adchoices opt-out tool. To learn more or to opt-out of tailored advertising please visit www.youradchoices.ca for information on how you can opt out of behavioural tracking on or through the Platform and how we respond to browser signals and other mechanisms that help users exercise their choices about behavioural tracking. The information we collect automatically is statistical information that may include personal information. We may maintain it or associate it with personal information we collect in other ways, that you provide to us, or receive from third parties. This usage information helps us to improve our Platform and to deliver a more personalized service, including by helping us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences and customize our Platform according to your individual preferences.
• Speed up your searches.
• Recognize you when you use the Platform.

If you do not want us to collect this information do not download or use any part of the Platform.

4. HOW WE USE YOUR INFORMATION

We use information that we collect about you or that you provide to us, including any personal information:

• for profile verification to create a User account.
• To provide you with the Platform and its contents.
• To provide you with information, products or services that you request from us.
• To fulfill the purposes for which you provided it or that were described when it was collected or any other purpose for which you provide it.
• To provide notices about your account, including expiration and renewal notices
• To carry out our obligations and enforce our rights in any contracts with you, including for billing and collection or to comply with legal requirements.
• To notify you when App updates are available, and of changes to any products or services we offer or provide though it.
• To improve our Platform, products or services, or customer relationships and experiences.
• For marketing purposes.
• To allow you to participate in interactive features, social media, or other features on our Platform.
• To measure or understand the effectiveness of the advertising we serve to you and others, and to deliver relevant advertising to you.
• For any other purpose with your consent.

Usage information that we collect helps us to improve our Platform and to deliver a better and more personalized experience, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Platform according to your individual interests.
• Speed up your searches.
• Recognize you when you use the Platform.

We use location information we collect to match you with other Users that are close in proximity to you. We may also use your information to contact you about our own and third parties’ goods and services that may be of interest to you, as permitted by law. If you do not want us to use your information in this way, please adjust your user preferences in your account profile, use the unsubscribe mechanism at the bottom of our emails, and or email us at privacy@tuktu.ca For more information, see Choices About How We Use and Disclose Your Information. We may use the information we have collected from you to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria. If you click on any third party sites, you acknowledge and agree that you are subject to the privacy policies of those third party sites. You should always read the terms of service or terms and conditions as well as the privacy policy of any site that you visit. Tuktu is not responsible or liable for any matters related to the collection of your information on such third party sites.

5. PROFILE VERIFICATION INFORMATION

For safety and security and to ensure Users have the best possible user experience, we require Users to verify their accounts by providing certain personal information referenced above, such as your phone number and your photo verification. We want to ensure that Users are not creating fake accounts which can be used for malicious activities and cybercrime.

6. DISCLOSURE OF YOUR INFORMATION

We may disclose aggregated information about our Users, and information that does not identify any individual, without restriction. We may disclose personal information that we collect or you provide as described in this privacy policy:

• To our subsidiaries and affiliates.
• According to applicable law, to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Tuktu’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Tuktu about our customers and users is among the assets transferred.
• To advertisers and advertising networks that require the information to select and serve relevant advertisements to you and others. We do not disclose data about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 400 women between 30 and 45 have clicked on their advertisement on a specific day). We may also use such aggregate information to help advertisers target a specific audience (for example, men in a specific location). We may use the personal information we collect from you to display our advertisers’ advertisements to their target audiences.
• To contractors, service providers, and other third parties we use to support our business, such as analytics and search engine providers that help us optimize and improve our services. We contractually require these third parties to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process personal information following the same standards set out in this policy
• To fulfill the purpose for which you provide it. For example, if you give us an email address to use the “email a friend” feature, we will transmit the contents of that email and your email address to the recipients.
• For any other purpose we disclose when you provide the information.
• With your consent.
• To comply with any court order, law, or legal process, including to respond to any government or regulatory request, according to applicable law. It is important that Users behave in accordance with the Terms and Conditions while using the Platform. We will cooperate with all third parties to enforce their intellectual property or other rights. We will also cooperate with law enforcement where we are required to by law, where there is an investigation into alleged criminal behaviour or to protect the vital interests of a person. This may include preserving or disclosing your information, including your personal information, if we believe in good faith that it is necessary to comply with a judicial proceeding, court order, or legal request; to protect the safety of any person; to address fraud, security or technical issues (for example, anti-spam providers to protect the service from criminal activity or to protect our rights or property or those of third parties.
• To enforce our rights arising from any contracts between you and us and for billing and collection.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Tuktu, our customers, or others. This includes exchanging information with other companies and organizations for fraud prevention and credit risk reduction.

7. TRANSFERRING YOUR PERSONAL INFORMATION

We may transfer personal information that we collect or that you provide us to contractors, service providers, and other third parties we use to support the Platform (such as analytics providers that assist us with Platform improvement and optimization) and who are contractually obligated to keep personal information confidential, to use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy. We may process, store, and transfer your personal information in and to other countries with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information. Whenever we engage a service provider, we require that its privacy and security standards comply with this policy and applicable Canadian laws. By submitting your personal information or engaging with the Platform, you consent to this transfer, storage, or processing.

8. CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. You can choose whether to allow the Platform to collect information through other tracking technologies by adjusting the opt-out methods available to you under your account's Settings. If you disable or refuse cookies or block the use of other tracking technologies some parts of the Platform may not be accessible or may not function properly. For more information about tracking technologies, see Automatic Information Collection and Tracking Technologies.
• Location Information. You can choose whether to allow the Platform to collect and use real-time information about your device’s location through the device's privacy settings. If you block the use of location information, some parts of the Platform may be inaccessible or not function properly. If you have given Tuktu access to your location, but wish to turn this off, you can do so by visiting the privacy settings of your device. If you require assistance, you should contract your device/service provider. You can also email privacy@tuktu.ca.
• Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt out by adjusting the opt-out methods available to you under your account's Settings. You can also always adjust your user advertising preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to privacy@tuktu.ca.

We do not control third parties’ collection or use of your information to serve behavioural advertising. These third parties may provide you with additional choices about how they use your information or ways to choose not to have your information collected or used in this way. You can opt out of several third party ad servers’ and networks’ cookies simultaneously by using an opt-out tool created by the Digital Advertising Alliance of Canada and/or an opt-out tool created by the Network Advertising Initiative. You can also access these websites to learn more about online behavioural advertising and how to stop websites from placing cookies on your device. Opting out of a network does not mean you will no longer receive advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.

9. DATA SECURITY

The security of your personal information is very important to us. We use physical, electronic, and administrative measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. The safety and security of your information also depends on you. Where we have given you (or you have chosen) a password for access to certain parts of our Platform, you are responsible for keeping it confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Platform like message boards, which any Platform visitor can view. Unfortunately, the transmission of information via the Internet and mobile platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through the Platform. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any Platform privacy settings or security measures.

10. DATA LOCATIONS

We only collect information from Users using the Platform in Canada. We store all information collected through the Platform (including your personal information) in data centers owned by third parties located in Ohio, United States. We ensure that the data is adequately protected by ensuring that valid, legal mechanisms are in place. If you want more information about the storage of your data, please contact privacy@tuktu.ca.

11. DATA RETENTION

Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize or aggregate your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.

12. PERSONS UNDER THE AGE OF 19

Our Platform is not intended for persons under 19 years of age. No one under age 19 may provide any personal information to or on the Platform. We do not knowingly collect personal information from persons under 19. If you are under 19, do not use or provide any information on the Platform or on or through any of its features. If we learn we have collected or received personal information from a person under 19 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 19, please contact us at privacy@tuktu.ca.

13. ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes. By law you have the right to request access to and to correct the personal information that we hold about you. You can review and change your personal information by logging into the Platform and visiting your account profile page. If you want to review, verify, correct, or withdraw consent to the use of your personal information you may also send us an email at privacy@tuktu.ca to request access to, correct, or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. We may charge you a fee to access your personal information, however, we will notify you of any fee in advance. We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions. We will provide access to your personal information, subject to exceptions set out in applicable privacy legislation. Examples of such exceptions include:

• Information protected by solicitor-client privilege.
• Information that is part of a formal dispute resolution process.
• Information that is about another individual that would reveal their personal information or confidential commercial information.
• Information that is prohibitively expensive to provide.

If you are concerned about our response or would like to correct the information provided, you may contact our Privacy Officer at privacy@tuktu.ca. If you delete your User Contributions from the Platform, copies of your User Contributions may remain viewable in cached and archived pages or might have been copied or stored by other Platform users. Proper access and use of information provided on the Platform, including User Contributions, is governed by our terms of use www.tuktu.ca/terms-of-use

14. WITHDRAWING YOUR CONSENT

Where you have provided your consent to the collection, use, and transfer of your personal information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us at privacy@tuktu.ca. Please note that if you withdraw your consent we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you make your decision.

15. CHANGES TO OUR PRIVACY POLICY

We may update our privacy policy from time to time. It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users’ personal information, we will post the new privacy policy on this page. If you have provided your email to us, we will notify you of material changes by email. We include the date the privacy policy was last revised at the top of the page. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you, and for periodically visiting this privacy policy to check for any changes.

16. CONTACT INFORMATION AND CHALLENGING COMPLIANCE

We welcome your questions, comments, and requests regarding this privacy policy and our privacy practices. Please contact us at: Rustam Sengupta Tuktu Care Inc. 170-422 Richards Street Vancouver, BC, V6B 2Z4 CANADA +1 888-444-5945 privacy@tuktu.ca We have procedures in place to receive and respond to complaints or inquiries about our handling of personal information and our compliance with this policy and with applicable privacy laws. To discuss our compliance with this policy please contact our privacy officer using the contact information listed above.