Cotrawell
Privacy Policy
This Privacy Policy explains how Cotrawell Inc. (“we,” “us,” “Cotrawell”) collects, uses, discloses, and protects personal information in connection with the Service, in accordance with the Personal Information Protection and Electronic Documents Act (“PIPEDA”) and other applicable Canadian federal law. Ontario does not currently have a standalone private-sector privacy statute, so PIPEDA governs our handling of personal information in the course of commercial activity.
1. Scope
1.1 This Policy applies to personal information collected through the Service from Requesters, Providers, and other visitors (“you”). It does not apply to information collected by third parties, including other Users, once shared outside the Service, or to a Provider’s or Requester’s own handling of information exchanged in connection with an Underlying Service, which is outside our control.
2. Who We Are
2.1 Cotrawell Inc. is the organization accountable for personal information under our control. Compliance is overseen by our designated Privacy Officer, reachable at privacy@cotrawell.com, 150 Duncan Mill Road, Toronto, ON M3B 3M4.
3. Personal Information We Collect
We collect the following categories of personal information:
3.1 Identity Verification Data — name, date of birth, government-issued ID information, photograph, and related verification data submitted during account registration or identity-verification checks.
3.2 Trip Details — transport mode (flight, train, bus), route, dates and times, Hustle category requested or offered, and related booking references you choose to provide.
3.3 Location Data — approximate or precise device location, where enabled, used to match Requesters and Providers and to support in-Trip coordination (e.g., an Airport Guide locating a Requester).
3.4 Payment Data — billing information and transaction data associated with payment of the Lead Fee, processed via our third-party payment processor. We do not directly store full payment card numbers.
3.5 Communications — messages, call metadata, and other communications exchanged between Users through the Service, and correspondence you have with us (e.g., support requests).
3.6 Usage and Device Data — log data, device identifiers, and analytics data collected via cookies and similar technologies (see our Cookie Policy).
4. How We Collect Information
4.1 Directly from you when you register, post or accept a Trip, message another User, or contact support.
4.2 Automatically through your use of the Service (device/usage data, cookies).
4.3 From third parties, such as identity-verification providers, payment processors, and, where you use them, third-party log-in services.
5. Purposes for Collection, Use, and Disclosure
Consistent with PIPEDA’s accountability and identifying-purposes principles, we collect, use, and disclose personal information only for purposes a reasonable person would consider appropriate in the circumstances, including to:
5.1 create and administer your account and verify your identity;
5.2 match Requesters with Providers and facilitate an introduction;
5.3 process and collect the Lead Fee;
5.4 enable in-Service communication between matched Users;
5.5 provide customer support and respond to inquiries or complaints;
5.6 detect, investigate, and prevent fraud, abuse, or violations of the Terms;
5.7 comply with legal obligations, including responding to lawful requests from public authorities;
5.8 improve and analyze the Service (aggregated/de-identified where feasible); and
5.9 send Service-related notices and, where you have consented, marketing communications.
6. Consent
6.1 We obtain your consent — express or implied, as appropriate to the sensitivity of the information — before or at the time of collection. Providing identity verification data, trip details, and payment data is generally required to use the Service; where information is optional, we will indicate this.
6.2 You may withdraw consent at any time, subject to legal or contractual restrictions, by contacting our Privacy Officer. Withdrawing consent for certain data (e.g., identity verification) may mean we can no longer provide the Service to you.
6.3 Consent for non-essential cookies (analytics, marketing/advertising) is managed separately as described in our Cookie Policy, consistent with PIPEDA’s requirement for meaningful, informed consent.
7. Disclosure to Third Parties
7.1 To other Users. When a match occurs, we share limited profile information (e.g., name, photo, relevant Trip and Hustle details, and — where a Hustle requires it — approximate location) between the matched Requester and Provider so they can coordinate. We do not disclose full identity-verification data or payment data to other Users.
7.2 To service providers. We share information with third parties who perform services on our behalf, such as identity-verification vendors, payment processors, hosting providers, and analytics providers, under contractual obligations to protect that information and use it only for the purposes we specify.
7.3 For legal reasons. We may disclose information where required by law, court order, or lawful government request, or to protect the rights, safety, or property of the Platform, our Users, or the public.
7.4 Business transfers. In the event of a merger, acquisition, or sale of assets, personal information may be transferred as part of that transaction, subject to equivalent protections.
7.5 We do not sell personal information to third parties for their own independent marketing purposes.
8. Cross-Border Transfers
8.1 Some third-party service providers (e.g., payment processors, cloud hosting) may store or process personal information outside Canada, including in the United States. Where this occurs, that information may become subject to the laws of the foreign jurisdiction, including lawful access by foreign authorities. We take contractual and technical steps to require a comparable level of protection.
9. Retention
9.1 We retain personal information only as long as necessary to fulfil the purposes described in this Policy, or as required by law (e.g., tax and accounting records), after which it is securely deleted or anonymized.
10. Security Safeguards
10.1 We use physical, organizational, and technological safeguards appropriate to the sensitivity of the information, including encryption in transit, access controls, and staff confidentiality obligations. No system is completely secure, and we cannot guarantee absolute security.
11. Your Rights
Subject to limited exceptions under PIPEDA, you have the right to:
11.1 Access the personal information we hold about you;
11.2 Correct inaccurate or incomplete personal information;
11.3 Withdraw consent to further collection, use, or disclosure (see Section 6.2); and
11.4 Request deletion of personal information we no longer need for an identified purpose or that we are not otherwise required to retain.
11.5 To exercise these rights, contact our Privacy Officer at privacy@cotrawell.com. We will respond within the time required by PIPEDA and may need to verify your identity before acting on a request.
11.6 If you are not satisfied with our response, you may file a complaint with the Office of the Privacy Commissioner of Canada (priv.gc.ca).
12. Minors and Vulnerable Individuals
12.1 The Service is intended for use by individuals 18 years of age or older and is not directed at children. Where a Hustle involves a minor or vulnerable adult (e.g., Parent’s Helper (Supervised), Airport Transit Assistance (Seniors)), the User account holder — not the minor or vulnerable individual — is the party interacting with the Service, and is responsible for any personal information about that third party that they choose to share with a Provider. We do not knowingly collect personal information directly from children.
14. Changes to This Policy
14.1 We may update this Policy from time to time. Material changes will be notified through the Service or by email, with an updated effective date.
15. Contact Us
Attn: Privacy Officer, Cotrawell Inc. Email: privacy@cotrawell.com Address: 150 Duncan Mill Road, Toronto, ON M3B 3M4
If you are not satisfied with our response to a privacy concern, you may contact the Office of the Privacy Commissioner of Canada.