MRDRIVER – INSTRUCTOR PRIVACY POLICY

Last updated 19 April 2025

This Privacy Policy explains how MrDriver ("Company," "we," "us") collects, uses, shares and protects personal information about driving instructors ("Instructor," "you") who use the MrDriver Instructor App and related services (collectively, the "Platform").

We comply with Canada's Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy laws.

1. Scope

This Policy applies only to data processed in connection with the Instructor version of the MrDriver Platform. A separate Privacy Policy governs student data.

2. What Information We Collect

Category Examples Source
Account Data Name, email, phone, password Provided by you
Professional Profile Ontario instructor licence number & expiry, MTO-approved Driving Instructor License, G‑class driver's licence, years of driving experience, insurance policy details, vehicle make/model/plate, profile photo Provided by you; manually verified by MrDriver compliance team
Banking & Payout Data Bank transit/institution/account numbers (EFT) or debit‑card PAN (last 4 digits), account holder name, payout history Provided by you; transaction data generated by MrDriver finance system
Booking & Earnings Data Lesson dates, times, locations (city), Student PINs, Service Fees, net payouts Generated by your activity
Usage & Analytics Login timestamps, feature interactions, crash logs, device OS, IP address Collected automatically via Firebase Analytics & Crashlytics
Location Data (optional) Latitude/longitude captured when you start Lesson tracking after entering Student PIN Collected when you enable tracking
Chat Data Messages exchanged with Students and MrDriver support inside the App Generated by your use
Support Data Emails, tickets, attachments, call recordings Generated when you contact us

We do not knowingly collect data about children (< 13 years) in the Instructor App.

3. How We Use Your Information

Purpose Legal Basis*
Verify eligibility and create your Instructor account Consent; Contract performance
Display your profile to prospective Students (first name, photo, rating, vehicle) Consent; Contract performance
Schedule Lessons, process bookings and cancellations Consent; Contract performance
Calculate Service Fees, process manual payouts via EFT or Push‑to‑Debit Consent; Contract performance; Legitimate interests (business operations)
Validate instructor licence status and insurance compliance Legal obligation; Legitimate interests (platform safety)
Provide in‑App chat, notifications and support Consent; Legitimate interests
Monitor compliance with Instructor Terms (lesson tracking, PIN use) Legitimate interests
Improve and secure the Platform (analytics, fraud detection) Legitimate interests
Send policy updates or marketing (opt‑in) Consent (CASL)
Meet legal, tax and regulatory obligations (CRA, MTO) Legal obligation

*Under PIPEDA, "legitimate interests" refers to reasonable business purposes that a reasonable person would consider appropriate in the circumstances.

4. How We Share Your Information

  1. Students. We share only your first name, profile photo, rating, vehicle details, city and brief bio with Students. Your phone number, email and banking data are not shared.
  2. Service Providers.
    • Google Firebase – authentication, analytics, crash reporting, push notifications.
    • Payment processors / banks – to execute EFT or Debit payouts.
    All providers are bound by confidentiality agreements and may use data solely to provide services to us.
  3. Insurance Partners. Aggregate, de‑identified claim data may be shared to maintain coverage. No personal banking data is disclosed.
  4. Legal & Safety. We may disclose information if required by law, court order or to defend our rights or those of a third party (e.g., collision report, insurance claim, CRA audit).
  5. Business Transfers. Data may transfer to a successor entity in a merger, acquisition or asset sale subject to this Policy.

We never sell Instructor personal information.

5. International Transfers

MrDriver's primary servers are located in Canada, but some service providers (e.g., Firebase) process data in the United States or other jurisdictions. When they do, your data is subject to local laws, and foreign authorities may access it under lawful orders. We use contractual and technical safeguards to protect cross‑border transfers.

6. Security Measures

  • Encryption in transit & at rest for sensitive data.
  • Role‑based access controls and audit logs for staff.
  • Manual verification of instructor documents occurs in a secure review portal accessible only to compliance personnel.
  • Incident‑response plan with breach notification to affected users and regulators within required timelines.

7. Data Retention

  • Instructor account records – retained for the life of the account plus seven (7) years for tax and employment‐standards compliance.
  • Payout and financial data – seven (7) years to satisfy CRA audit requirements.
  • Chat & support data – three (3) years after ticket closure.
  • Anonymised or aggregated data may be kept indefinitely.

8. Your Rights & Choices

  1. Access & Correction. View/update most information in the App; email support@mrdriver.ca for a full report or correction.
  2. Withdraw Consent. You may withdraw consent for non‑essential processing; this may limit your ability to use the Platform.
  3. Deletion. Request account deletion; we will remove or anonymise data not required for legal compliance.
  4. Marketing Opt‑Out. Toggle marketing preferences in the App or use the unsubscribe link in any email.
  5. Cookie/Tracking Controls. Disable analytics cookies via browser or device settings; essential cookies cannot be turned off.

We respond to verified requests within 30 days.

9. Cookies & Similar Technologies

The Instructor App uses:

  • Essential cookies/sdk storage – for authentication and security.
  • Analytics cookies – Firebase Analytics (you can opt‑out in settings).
  • Messaging tokens – for push notifications about bookings.

10. Changes to This Policy

We may update this Policy from time to time. Material changes will be announced by email and in‑App notice 15 days before they take effect. The "Last updated" date reflects the latest revision.

11. Contact & Complaints

Privacy Officer
MrDriver
145 ½ Church Street, Unit 5 Office 32
Toronto ON M5B 1Y4 Canada
✉️ support@mrdriver.ca
☎️ 1‑647-523-2391

If we cannot resolve your complaint, you may contact the Office of the Privacy Commissioner of Canada (OPC) at 1‑800‑282‑1376 or priv.gc.ca.

By using the MrDriver Instructor App, you acknowledge that you have read and understood this Instructor Privacy Policy.

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