Canadian Academy of Defensive Driving Inc. ("CADD," "we," "us," or "our") is committed to protecting your privacy and safeguarding your personal information. This Privacy Policy explains how we collect, use, disclose, and protect personal information when you visit our website (caddonline.greenhardwares.com), enrol in our programs, interact with our advertisements on social media and other platforms, or otherwise engage with our services.
This Privacy Policy is designed to comply with Canada's Personal Information Protection and Electronic Documents Act (PIPEDA), Canada's Anti-Spam Legislation (CASL), the Ontario Freedom of Information and Protection of Privacy Act (FIPPA) where applicable, and all other applicable federal and provincial privacy laws. By accessing our website, submitting information through our forms, enrolling in our courses, or interacting with our advertisements, you acknowledge that you have read and understood this Privacy Policy.
1. Information We Collect
We collect personal information that is necessary to provide our driver education services, comply with legal obligations, and improve your experience. The information we collect may include:
1.1 Personal Identifiers
1.2 Driver's Licence and Driving Information
1.3 Financial Information
1.4 Course and Service Records
1.5 Communication Records
1.6 Website Usage Data and Analytics
1.7 Social Media and Advertising Data
How We Use Your Information
We use your personal information for the following purposes:
2.1 Service Delivery
2.2 Communication
2.3 Marketing and Advertising (With Consent)
2.4 Legal and Regulatory Compliance
2.5 Business Operations and Improvement
3. Legal Basis for Processing
Under PIPEDA and applicable Canadian privacy laws, we process personal information based on the following legal grounds:
4. Consent
By providing your personal information to us, whether through our website, over the phone, in person, or through social media lead forms and advertisements, you consent to the collection, use, and disclosure of your information as described in this Privacy Policy.
4.1 Express Consent
We obtain express consent when you:
4.2 Implied Consent
In certain circumstances, we may rely on implied consent, such as when you voluntarily provide your information to inquire about our services, or when you continue to use our services after being notified of changes to this Privacy Policy.
4.3 Withdrawing Consent
You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice. To withdraw consent for marketing communications, you may:
Please note that withdrawing consent for certain uses may prevent us from providing you with our services. We will inform you of the consequences of withdrawing consent at the time of your request.
5. How We Share Your Information
We do not sell, rent, or trade your personal information to third parties for their own marketing purposes. We may share your personal information only in the following circumstances:
5.1 Ministry of Transportation (MTO)
We are required by Ontario law to submit student records, certification data, and completion information directly to the MTO for all MTO-approved courses, including the Beginner Driver Education (BDE) program and Driver Improvement programs.
5.2 Courts and Legal Authorities
For court-mandated Driver Improvement programs, we share completion certificates and attendance records with the referring court or legal representative, as required by law. We may also disclose information if required by subpoena, court order, or to protect our legal rights.
5.3 Service Providers
We engage trusted third-party service providers to perform functions on our behalf, including:
These service providers are contractually bound to protect your personal information, use it only for the purposes for which it was disclosed, and comply with applicable privacy laws.
5.4 Social Media and Advertising Platforms
When you interact with our advertisements on social media platforms (including Facebook, Instagram, LinkedIn, and YouTube), these platforms may collect and process your information in accordance with their own privacy policies. We may share hashed or aggregated data with these platforms for advertising optimisation, audience building, and conversion tracking purposes.
5.5 Business Transfers
In the event of a merger, acquisition, sale of assets, or other business transaction, your personal information may be transferred to the acquiring entity, subject to applicable privacy laws.
5.6 Law Enforcement and Safety
We may disclose personal information to law enforcement agencies or other authorities if required by law or if we believe in good faith that such disclosure is necessary to:
6. Social Media Advertising and Lead Generation
We advertise our services on social media platforms, including but not limited to Facebook, Instagram, LinkedIn, and YouTube. This section explains how we collect and use information through these advertising activities.
6.1 Facebook and Instagram Lead Ads (Meta Platforms)
We use Facebook Lead Ads and Instagram Lead Ads to connect with prospective students. When you interact with our lead ads:
6.2 Facebook and Instagram Lead Ads (Meta Platforms)
We use the Meta Pixel (formerly Facebook Pixel) and similar tracking technologies on our website to:
The Meta Pixel collects data about your browsing behaviour on our website, including pages visited, actions taken, and device information. This data is shared with Meta in accordance with Meta's Business Tools Terms. You can opt out of Meta Pixel tracking by adjusting your browser settings or visiting Meta's Ad Preferences page.
6.3 LinkedIn Advertising
We may use LinkedIn advertising services to reach prospective students. When you interact with our LinkedIn ads, LinkedIn may collect and process your information in accordance with LinkedIn's Privacy Policy and Cookie Policy. We may use LinkedIn Insight Tag for conversion tracking and audience optimisation.
6.4 YouTube Advertising
We may advertise on YouTube through Google Ads. Google's use of advertising cookies enables it and its partners to serve ads based on your visit to our website and other sites on the Internet. You may opt out of personalised advertising by visiting Google's Ad Settings.
6.5 Third-Party Data Sharing for Advertising
When we use social media advertising platforms, these platforms may act as independent data controllers for the data they collect directly from you. We encourage you to review the privacy policies of these platforms to understand how they handle your personal information:
7. Cookies and Tracking Technologies
Our website uses cookies and similar tracking technologies to enhance your browsing experience, analyse site traffic, understand user behaviour, and support our advertising activities.
7.1 Types of Cookies We Use
7.2 Your Cookie Choices
You can manage your cookie preferences through your browser settings. Most browsers allow you to refuse or delete cookies. Please note that disabling certain cookies may affect the functionality of our website and your user experience.
7.3 Do Not Track Signals
Our website does not currently respond to "Do Not Track" signals from browsers. However, you can opt out of certain tracking activities using the mechanisms described in this Privacy Policy or by adjusting your browser settings.
8. Data Security
We implement industry-standard administrative, technical, and physical security measures to protect your personal information from unauthorized access, alteration, disclosure, or destruction. These measures include:
While we strive to protect your personal information, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security, and you provide your information at your own risk.
9. Data Retention
We retain your personal information for as long as necessary to fulfil the purposes outlined in this Privacy Policy, comply with legal obligations, resolve disputes, and enforce our agreements. Specifically:
10. Your Privacy Rights
Under PIPEDA and applicable Canadian privacy laws, you have the following rights regarding your personal information:
10.1 Right to Access
You have the right to request access to the personal information we hold about you. We will provide this information within a reasonable timeframe and in a format that is easy to understand, subject to limited exceptions permitted by law.
10.2 Right to Correction
You have the right to request corrections to any inaccurate or incomplete personal information we hold about you. We will make the necessary corrections promptly and, where appropriate, notify any third parties to whom the information has been disclosed.
10.3 Right to Deletion
You may request the deletion of your personal information, subject to our legal and contractual obligations to retain certain records (e.g., MTO-required student records). We will inform you of any restrictions on deletion.
10.4 Right to Withdraw Consent
You may withdraw your consent for the collection, use, or disclosure of your personal information at any time, subject to legal or contractual restrictions and reasonable notice. Withdrawing consent may affect our ability to provide certain services to you.
10.5 Right to Complain
If you believe your privacy rights have been violated, you have the right to file a complaint with us or with the Office of the Privacy Commissioner of Canada (OPC). We will cooperate fully with any investigation conducted by the OPC.
10.6 Exercising Your Rights
To exercise any of these rights, please contact us using the information provided in Section 15. We may require you to verify your identity before processing your request.
11. Canada's Anti-Spam Legislation (CASL) Compliance
In compliance with Canada's Anti-Spam Legislation (CASL), we adhere to the following principles for all commercial electronic messages (CEMs), including marketing emails, text messages (SMS), and social media direct messages:
11.1 Consent Requirement
We will not send you CEMs without your express or implied consent. When you provide your contact information and opt in to marketing communications, you are giving us express consent to send you CEMs.
11.2 Identification Requirement
All CEMs will clearly identify Canadian Academy of Defensive Driving Inc. as the sender and provide our valid contact information, including our business name, mailing address, and contact details.
11.3 Unsubscribe Mechanism
Every CEM will include a clear and functional unsubscribe mechanism that allows you to opt out of receiving future messages. Unsubscribe requests will be processed within ten (10) business days or less.
11.4 Record Keeping
We maintain records of consent, including the date, time, and method of consent, in accordance with CASL requirements.
12. Children's Privacy
Our services are directed to individuals aged 16 and older, or to parents and guardians enrolling minors in driver education programs. We do not knowingly collect personal information from children under the age of 13 without verifiable parental consent. If we become aware that we have inadvertently collected personal information from a child under 13 without appropriate consent, we will take steps to delete such information promptly.
13. Cross-Border Data Transfers
Your personal information may be processed and stored in Canada or transferred to service providers located in other jurisdictions, including the United States. When personal information is transferred outside of Canada, we ensure that appropriate safeguards are in place to protect your information in accordance with applicable privacy laws. By using our services, you consent to the transfer of your information to jurisdictions outside of Canada.
14. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or business operations. Material changes will be posted on this page with an updated effective date. We encourage you to review this Privacy Policy periodically. Your continued use of our services after any changes constitutes your acceptance of the revised Privacy Policy.
15. Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy, or if you wish to exercise your privacy rights, please contact us:
Canadian Academy of Defensive Driving Inc.
Attention: Privacy Officer
Address: 67 Victoria Wood Avenue, Markham, Ontario L6E 1K2
Email: privacy@caddonline.ca
Phone: (416) 642-8549
Website: https://caddonline.ca
You may also contact the Office of the Privacy Commissioner of Canada:
Website: https://www.priv.gc.ca
Phone: 1-800-282-1376
