CurbMate Privacy Policy

1. What Is Personal Information?

“Personal information” means information about an identifiable individual.

Depending on how you interact with CurbMate, this may include your:

• name;
• email address;
• telephone number;
• home or service address;
• postal code;
• neighbourhood;
• billing information;
• subscription information;
• property-access information;
• container-location information;
• communications with CurbMate; and
• other information that can reasonably be connected to you.

Personal information generally does not include business contact information used solely for business purposes where applicable law excludes that information.

2. Information We Collect

CurbMate collects only information that is reasonably necessary for the purposes described in this Privacy Policy.

Contact Information

We may collect:

• first and last name;
• email address;
• telephone number; and
• other contact information you voluntarily provide.

We use this information to communicate with you and administer your relationship with CurbMate.

3. Waitlist Information

When you join the CurbMate waitlist, we may collect:

• your name;
• email address;
• postal code;
• neighbourhood;
• general service location;
• plan interest; and
• marketing preferences.

We use this information to:

• manage the waitlist;
• determine where customer demand exists;
• evaluate future service areas and routes;
• determine whether service becomes available in your area;
• notify you about your waitlist status;
• invite you to activate service; and
• provide promotional communications where we have the appropriate consent.

Joining the waitlist does not automatically create a paid subscription.

We do not require payment information solely to join the waitlist.

4. Service Address Information

Customers who activate CurbMate service must provide information necessary for us to identify and service their property.

This may include:

• street address;
• unit number where applicable;
• postal code;
• municipality;
• neighbourhood; and
• other information necessary to identify the service location.

We use this information to:

• determine service eligibility;
• establish service routes;
• identify applicable municipal collection schedules;
• provide bin-valet service;
• coordinate service visits; and
• communicate about service-related issues.

5. Container Location and Property Access Information

Because CurbMate moves containers from their normal storage location to the municipal collection point and returns them afterward, we may collect information about where containers are located on your property.

This may include:

• whether containers are stored on the left or right side of a house;
• front-yard or backyard location;
• driveway location;
• designated storage area;
• gate information;
• pathway information;
• exterior access instructions;
• written directions;
• property notes; and
• other information reasonably necessary to locate and access your containers.

If CurbMate permits customers to submit photographs or diagrams of their property, any information contained in those submissions may also be treated as personal information.

We use this information only for purposes reasonably connected to providing, improving, administering, or safely performing CurbMate services.

Customers should not provide unnecessary sensitive information, alarm codes, interior access information, or other information that CurbMate has not requested.

6. Municipal Collection Information

CurbMate may associate your service address with publicly available municipal collection information, including:

• garbage collection days;
• organics collection days;
• recycling collection days;
• holiday schedule changes; and
• applicable municipal collection zones.

This information is used to determine when CurbMate services should be performed.

7. Account and Subscription Information

When you subscribe to CurbMate, we may collect information including:

• selected service plan;
• subscription status;
• start date;
• renewal date;
• cancellation status;
• promotional eligibility;
• transaction history;
• service history; and
• account preferences.

We use this information to administer your subscription and provide your selected services.

8. Payment Information

CurbMate may use third-party payment processors, such as Stripe, to process subscription payments.

Payment information may include:

• payment method information;
• billing name;
• billing address;
• transaction amount;
• payment status;
• transaction identifiers; and
• limited payment-method information.

Where payment information is entered directly into a third-party payment processor's system, CurbMate may not receive or store your complete credit or debit card number.

Payment providers process information according to their own privacy policies and security practices.

CurbMate may retain transaction records reasonably necessary for accounting, subscription administration, fraud prevention, dispute resolution, taxation, and legal compliance.

9. Communications With CurbMate

When you contact us, we may retain information contained in the communication.

This can include communications through:

• email;
• website forms;
• customer-support requests;
• text messages;
• social media;
• subscription portals; and
• other communication channels.

We may use and retain these communications to:

• respond to your request;
• provide customer service;
• investigate service issues;
• maintain service records;
• resolve disputes;
• improve our operations; and
• comply with legal obligations.

10. Website Information

When you visit the CurbMate website, certain technical information may be collected automatically.

Depending on the technologies used on our website, this may include:

• IP address;
• browser type;
• device type;
• operating system;
• referring website;
• pages visited;
• approximate geographic region;
• date and time of access;
• website interactions; and
• similar technical information.

We may use this information to:

• operate the website;
• maintain security;
• understand website performance;
• troubleshoot technical issues;
• understand how visitors use the website;
• measure marketing effectiveness; and
• improve CurbMate's services.

11. Cookies and Similar Technologies

The CurbMate website may use cookies, pixels, tags, and similar technologies.

These technologies may be used for:

Essential website functions

These technologies help the website operate properly and may support functions such as security, account login, form submissions, or customer preferences.

Analytics

Analytics technologies may help us understand:

• how visitors reach the website;
• which pages are viewed;
• how visitors interact with the website; and
• where website improvements may be needed.

Advertising measurement

Where enabled, advertising technologies may help CurbMate understand whether an advertisement resulted in:

• a website visit;
• waitlist registration;
• service inquiry; or
• another conversion.

For example, CurbMate may use advertising platforms such as Meta to advertise its services and measure campaign performance.

Where consent is required for a particular technology, CurbMate will seek consent in accordance with applicable law.

Your browser or device may also allow you to restrict or disable certain cookies.

Disabling some technologies may affect website functionality.

12. How We Use Personal Information

CurbMate may use personal information for purposes including:

• providing CurbMate services;
• managing subscriptions;
• processing payments;
• identifying municipal collection schedules;
• establishing and optimizing service routes;
• locating containers;
• accessing designated exterior areas of customer properties;
• determining service availability;
• maintaining customer accounts;
• communicating about scheduled service;
• responding to customer questions;
• resolving missed-service or access issues;
• providing customer support;
• maintaining transaction and accounting records;
• administering promotions;
• operating the waitlist;
• measuring demand for service;
• improving our website and services;
• preventing fraud or misuse;
• protecting customers, personnel, and CurbMate;
• complying with legal obligations; and
• sending marketing communications where permitted.

We will not use personal information for a materially different purpose without obtaining additional consent where required by law.

13. Consent

CurbMate generally obtains consent before collecting, using, or disclosing personal information unless applicable law allows or requires us to act without consent.

Consent may be:

• express;
• implied; or
• otherwise permitted under applicable law.

The form of consent may depend on the circumstances and sensitivity of the information.

For example, when you voluntarily provide your service address so that CurbMate can provide service at that address, your consent to use that information for the obvious purpose of delivering the service may be implied.

CurbMate will not require you to consent to the collection, use, or disclosure of personal information beyond what is reasonably necessary to provide a product or service as a condition of receiving that product or service.

14. Marketing Communications

CurbMate may send promotional electronic communications where permitted by law.

These may include:

• launch announcements;
• promotional offers;
• discounts;
• new service-area announcements;
• referral offers;
• new service announcements; and
• other CurbMate marketing.

Where required, CurbMate will obtain consent before sending commercial electronic messages.

Marketing emails or messages will include an appropriate method for withdrawing consent or unsubscribing.

You may unsubscribe from promotional communications at any time.

Unsubscribing from marketing does not prevent CurbMate from sending necessary service communications, such as:

• subscription confirmations;
• payment information;
• service notices;
• account-security messages;
• route or access questions;
• cancellation confirmations; or
• other messages necessary to administer your service.

15. Waitlist Marketing Consent

Joining the CurbMate waitlist permits CurbMate to use the information you provide for purposes reasonably necessary to administer the waitlist and respond to your request to be notified about service availability.

Where CurbMate wishes to use your information for broader promotional marketing, we will obtain or rely upon consent as permitted by applicable Canadian law.

Where express marketing consent is requested, CurbMate will not use a pre-selected consent mechanism where a positive opt-in is legally required.

You may withdraw marketing consent at any time.

16. When We Share Personal Information

CurbMate does not sell or rent customer personal information.

We may disclose personal information to third parties where reasonably necessary to operate CurbMate or where permitted or required by law.

These third parties may include service providers that assist with:

• payment processing;
• website hosting;
• database hosting;
• cloud computing;
• email delivery;
• SMS communications;
• customer support;
• route management;
• mapping;
• analytics;
• advertising measurement;
• accounting;
• legal services; and
• business administration.

We seek to disclose only the information reasonably necessary for the third party to perform the applicable service.

17. Service Providers

Third-party service providers may process personal information on CurbMate's behalf.

CurbMate remains responsible for personal information under its custody or control as required by applicable law and will use reasonable measures appropriate to the circumstances when selecting and working with service providers.

Third-party providers may also have their own independent legal obligations regarding information they control.

18. Processing Outside British Columbia or Canada

Some service providers used by CurbMate may operate servers, employees, or facilities outside British Columbia or Canada.

As a result, personal information processed through those providers may be stored or processed in another province, the United States, or another jurisdiction.

Information located outside Canada may be subject to the laws of the jurisdiction in which it is processed and may be accessible to courts, law-enforcement agencies, or governmental authorities in accordance with applicable law.

Customers may contact CurbMate's Privacy Officer for additional information regarding our service providers and privacy practices.

19. Legal Disclosures

CurbMate may collect, use, or disclose personal information without additional consent where permitted or required by applicable law.

For example, information may be disclosed where reasonably necessary to:

• comply with a court order;
• comply with another legal requirement;
• respond to lawful governmental requests;
• investigate suspected fraud or unlawful activity;
• protect CurbMate's legal rights;
• respond to an emergency where permitted by law;
• obtain legal advice; or
• establish, exercise, or defend legal claims.

20. Business Transactions

If CurbMate undergoes a proposed or completed business transaction such as a:

• sale;
• merger;
• financing;
• reorganization;
• acquisition;
• transfer of assets; or
• similar transaction,

personal information may be disclosed or transferred where permitted by applicable privacy law and subject to appropriate safeguards and restrictions.

21. We Do Not Sell Personal Information

CurbMate does not sell customer names, home addresses, email addresses, telephone numbers, property information, or other personal information to data brokers or unrelated businesses for their independent marketing purposes.

22. Information Security

CurbMate uses reasonable administrative, technical, and physical safeguards appropriate to the nature of the personal information we hold.

These safeguards may include measures designed to protect information against:

• unauthorized access;
• unauthorized collection;
• unauthorized disclosure;
• loss;
• theft;
• copying;
• modification;
• misuse;
• destruction; and
• other similar risks.

Safeguards may include, where appropriate:

• password-protected systems;
• access controls;
• secure payment processors;
• encrypted connections;
• restricted employee or contractor access;
• account authentication;
• software and system security measures; and
• internal privacy procedures.

However, no electronic storage or transmission system can be guaranteed to be completely secure.

23. Privacy and Security Incidents

If CurbMate becomes aware of a privacy or security incident involving personal information, we will assess the circumstances and take reasonable steps appropriate to the nature of the incident.

These steps may include:

• containing the incident;
• investigating its cause;
• limiting further unauthorized access;
• correcting vulnerabilities;
• documenting the incident; and
• notifying affected individuals or authorities where required by law or otherwise appropriate.

24. How Long We Keep Personal Information

CurbMate keeps personal information only for as long as reasonably necessary to:

• provide services;
• administer subscriptions;
• maintain business and financial records;
• resolve disputes;
• meet legal obligations;
• protect legitimate business interests; or
• fulfill the purpose for which the information was collected.

Where personal information has been used to make a decision that directly affects an individual, CurbMate will retain that information for at least the period required by applicable law.

Under British Columbia's PIPA, information used to make a decision directly affecting an individual generally must be retained for at least one year after the decision so the individual has a reasonable opportunity to access it.

When personal information is no longer reasonably required, CurbMate will take reasonable steps to securely destroy, delete, or anonymize it, subject to legal and legitimate business retention requirements.

25. Waitlist Information Retention

CurbMate may retain waitlist information while:

• the applicable service area is being evaluated;
• the person remains on the waitlist;
• CurbMate reasonably expects to launch service in the applicable area; or
• the information remains reasonably necessary for the purposes explained when it was collected.

Individuals may contact CurbMate to request removal from the waitlist.

Where no further legal or legitimate business reason requires retention, CurbMate will delete or anonymize the information within a reasonable period.

26. Accuracy of Personal Information

CurbMate will make reasonable efforts to ensure personal information used to make decisions about customers or disclosed to others is accurate and complete.

Customers should keep their:

• service address;
• contact information;
• container location;
• access instructions; and
• account information

up to date.

You may contact us if you believe information we hold about you is inaccurate or incomplete.

27. Your Right to Access Personal Information

Subject to exceptions permitted by law, you may request access to personal information about you that is under CurbMate's control.

You may also request information about:

• how CurbMate has used your personal information; and
• persons or organizations to whom the information has been disclosed where required by applicable law.

Requests should be submitted to the CurbMate Privacy Officer using the contact information below.

CurbMate may need to verify your identity before responding to an access request.

28. Your Right to Request Corrections

You may request correction of errors or omissions in personal information under CurbMate's control.

Where CurbMate is satisfied that a correction should be made, we will correct the information as required by applicable law.

Where we do not make the requested correction, we will handle the request in accordance with applicable privacy law, which may include annotating the record to indicate that a correction was requested.

29. Withdrawal of Consent

You may withdraw consent to certain collection, use, or disclosure of your personal information by contacting CurbMate.

Withdrawal of consent is subject to:

• reasonable notice;
• contractual restrictions;
• legal requirements; and
• circumstances where the information remains necessary to provide a requested service.

For example, CurbMate cannot provide residential bin-valet service without knowing the property where the service is to be performed.

If you withdraw consent for information essential to providing the service, CurbMate may be unable to continue providing that service.

Withdrawal of consent does not affect collection, use, disclosure, or retention that is otherwise permitted or required by law.

30. Account Closure and Cancellation

Cancelling a CurbMate subscription does not necessarily require immediate deletion of all personal information associated with the account.

CurbMate may retain limited information after cancellation where reasonably necessary for purposes such as:

• completing the cancellation;
• accounting;
• tax records;
• transaction history;
• fraud prevention;
• dispute resolution;
• legal compliance; and
• establishing or defending legal claims.

Information that is no longer reasonably necessary will be deleted, destroyed, or anonymized in accordance with our retention practices.

31. Social Media

CurbMate may maintain accounts on social media platforms such as Facebook and Instagram.

Information you voluntarily submit through those platforms may also be subject to the platform provider's privacy practices.

Interactions with CurbMate through social media should not be used to provide sensitive access information, payment information, passwords, or other confidential information.

32. Third-Party Websites

The CurbMate website may contain links to websites operated by third parties.

CurbMate does not control the privacy practices of independent third-party websites.

Customers should review the privacy policy of any third-party website or service before providing personal information to that provider.

33. Children's Information

CurbMate's paid residential services are intended to be purchased by individuals who are legally able to enter into the applicable service agreement.

CurbMate does not knowingly seek to collect personal information from children where that information is unnecessary for providing our services.

If you believe a child has provided personal information to CurbMate inappropriately, please contact our Privacy Officer.

34. Changes to This Privacy Policy

CurbMate may update this Privacy Policy from time to time to reflect:

• changes to our services;
• changes to technology;
• changes to service providers;
• new privacy practices; or
• changes in applicable law.

The updated Privacy Policy will identify the date it was last revised.

Where a change materially affects how existing personal information will be used or disclosed, CurbMate will provide additional notice or obtain consent where required by law.

35. Questions or Privacy Complaints

Individuals may contact CurbMate with questions or complaints about how their personal information is handled.

CurbMate will maintain a process for receiving and responding to privacy concerns.

Please contact:

• CurbMate Privacy Officer
• Operated by: Haneul Oh & Ibrahim Burrow
• Website: CurbMate.ca
• Email: ouju1013@gmail.com
• Mailing Address: 2520 Blackwood st, Victoria, British Columbia, Canada

Please include enough information for us to understand and respond to your request, but do not send unnecessary sensitive information by unsecured email.

36. Office of the Information and Privacy Commissioner for British Columbia

If you have a concern about CurbMate's handling of personal information, we encourage you to contact our Privacy Officer first so we have an opportunity to address the issue.

You may also have the right to contact the Office of the Information and Privacy Commissioner for British Columbia (OIPC BC) regarding privacy matters within its jurisdiction.

37. Contact CurbMate

For general questions about CurbMate services:

• CurbMate
• Operated by: Haneul Oh & Ibrahim Burrow
• Website: CurbMate.ca
• General Email: curbmateisland@gmail.com
• Privacy Email: ouju1013@gmail.com
• Mailing Address: 2520 Blackwood st, Victoria, British Columbia, Canada