Privacy Policy (Canada)

1. Introduction

RouteBook LLC ("Routebook," "we," "our," "us") takes your privacy seriously. This Privacy Policy explains what information we collect when you use the Routebook mobile application and related services (the "Platform"), how we use that information, who we share it with, and what choices you have.

This Policy applies to users whose Routebook account country is Canada, including users resident in Quebec. Routebook handles personal information under applicable privacy laws, including PIPEDA and, where applicable, provincial private-sector privacy laws. Quebec residents may also have rights under Quebec's Act respecting the protection of personal information in the private sector (CQLR, c. P-39.1).

When personal information relating to Quebec residents is communicated outside Quebec, Routebook will conduct the assessment and put the required written safeguards in place under applicable Quebec law before the communication occurs.

By using the Platform, you agree to the collection, use, and disclosure of your personal information as described in this Policy and provide the consents described in Section 3.

2. Information We Collect

2.1 Information You Provide

Account Information

• Canadian mobile phone number (used as your primary account identifier; see our Terms of Service, Section 4.3)
• Profile photo (user-uploaded)
• A cryptographically derived credential used to attach your Firebase-authenticated sign-in session to your Routebook account. No password you type is stored, because there is no password to type — see Section 2.3.

Profile Information

• Bio or about-me text
• Travel preferences (e.g., preferences about music, smoking, pets)
• Country selection (Canada), used to apply the Canadian version of these policies, Canadian-dollar pricing, and Canadian payout setup

Identity-Verification Information

• Government-issued identity document (driver's licence, Canadian passport, or provincial photo identity card) and a real-time selfie. These are collected inside the Persona flow and transmitted directly to Persona Identities, Inc. They are not received or stored by Routebook. Persona retains them under Persona's own privacy and retention policies.
• From Persona's processing, Routebook receives and stores: your verification outcome (verified / requires input / canceled / age-ineligible), the document type submitted, the full name printed on the document, and your date of birth.
• Your Routebook profile name is automatically overwritten to the full name Persona extracts from your ID once verification succeeds.

Route Information

• Origin and destination of routes you post or search
• Departure dates and times
• Number of seats you post as available
• Recurring schedule preferences
• Vehicle information (make, model, year) — provided voluntarily by users posting routes

Ride Requests, Messages, Feedback

• Requests you send for a seat on another user's route, including any note you attach and the accept/decline/withdrawal state
• Content of messages you send through the in-app messaging feature
• Ratings and reviews you submit about other users; safety reports or support requests you submit to us

Payment Information

• When a Guest pays through Routebook, Stripe processes the payment and Routebook records payment, refund, and payout status. Stripe receives payment-card details directly; Routebook does not receive or store full card numbers or security codes. Hosts complete Stripe Connect onboarding to receive payouts. See Terms of Service, Section 5.7.

2.2 Information We Collect Automatically

Device and Usage Data

• Device identifiers (IDFA/GAID where permitted by your device settings)
• Device type, operating system version, and app version
• IP address
• App activity logs (screens viewed, features used, actions taken, session duration)
• Crash reports and performance diagnostics (collected via Sentry)

Push Notification Tokens. APNS and FCM push tokens issued by your device, relayed by the Expo Push Notification service.

Location Data. Coarse location derived from IP; precise GPS only when you grant permission and only while the app is in the foreground.

Cookies. The web version may use cookies to maintain your session and analyze usage patterns. Routebook does not run advertising SDKs or participate in cross-context behavioural advertising.

2.3 Information From Third Parties

• Firebase Authentication (Google LLC) — phone-number verification during sign-in.
• Persona (Persona Identities, Inc.) — government-ID + selfie verification; images stored by Persona only, not by Routebook.
• Google Maps Platform / Places — address geocoding, autocomplete, routing.
• Sentry — crash telemetry.
• Expo Push Notification service — push token relay.

3. Consent

By creating an account, you provide your express consent under PIPEDA (and under the Provincial PIPAs where applicable) to Routebook's collection, use, and disclosure of your personal information for the purposes described in this Policy. For each category of personal information, the applicable form of consent is as follows:

• Account registration, profile, routes, messages, and ride requests: express consent provided when you create your account. Required to operate the Platform.
• Identity verification (ID + selfie via Persona): express written consent provided when you initiate the Persona flow.
• Push notification tokens: implied consent, inferred from your device-level opt-in. You may withdraw at any time through your device settings.
• Precise location: express consent provided when you grant the operating-system location permission. You may withdraw at any time through your device settings.
• Automatic device and usage data; crash telemetry: implied consent, inferred from your use of the Platform. Used for security, debugging, and improvement. You may withdraw by deleting your account.
• Marketing communications: opt-in consent, obtained separately before any marketing message is sent. You may withdraw at any time via the unsubscribe link in any marketing email.

You may withdraw your consent to our collection, use, or disclosure of your personal information at any time, subject to legal or contractual restrictions and reasonable notice. Withdrawal of consent to information categories that are necessary to operate the Platform will result in termination of your account. To withdraw consent, contact us at [email protected] or delete your account through the app settings.

4. How We Use Your Information

We use the information we collect for the following purposes. Each use is limited to what a reasonable person would consider appropriate in the circumstances, consistent with PIPEDA Principle 4.4 (Limiting Collection) and 4.5 (Limiting Use, Disclosure, and Retention).

Operate the Platform — create and manage your account, display route postings in search, enable messaging, display profiles and reviews.

Improve the Platform — analyze usage patterns, fix bugs, test new features, generate aggregate analytics.

Communicate With You — send transactional notifications, respond to support requests, send marketing communications only with your prior opt-in consent and never without a readily available unsubscribe mechanism, in compliance with Canada's Anti-Spam Legislation (S.C. 2010, c. 23) ("CASL").

Safety and Enforcement — investigate reports of policy violations, detect fraud, enforce Terms and Community Guidelines.

Legal Compliance — comply with applicable federal, provincial, territorial, and foreign laws and valid legal process; protect Routebook's legal rights.

We will not use your personal information for a new purpose that is materially different from the purposes identified in this Policy without first obtaining your consent.

5. How We Share Your Information

We do not sell your personal information to third parties. We do not disclose your personal information to third parties for direct marketing or for use by third parties other than as described in this Section 5.

5.1 With Other Users

Your first name, profile photo, and any ratings or reviews you have received are visible on your public profile. Route details you post are visible to users who search for routes. Messages are visible only to the parties in that conversation. We do not share your email address, phone number, date of birth, or precise location with other users.

5.2 With Service Providers

We transfer personal information to third-party service providers who process it only to operate the Platform on our behalf under contractual data-protection obligations. Each is bound to use your information only for the purposes we specify and to protect it with a comparable level of protection as required by PIPEDA Principle 4.1.3 (Accountability for Transferred Information).

5.3 Cross-Border Transfer of Personal Information

Your personal information may be processed outside of Canada, primarily in the United States, by Routebook and its service providers. While your information is outside Canada, it may be subject to the laws of the jurisdiction in which it is held, including laws permitting access by law enforcement, courts, or government authorities under those laws. For information relating to Quebec residents, Routebook will complete any privacy impact assessment and enter into any written agreement required by Quebec law before communicating that information outside Quebec.

Routebook requires each service provider to protect your personal information with safeguards comparable to those described in this Policy. If you wish to obtain further information about the way personal information is handled by any specific service provider, contact us at [email protected].

5.4 Legal Requirements

We may disclose your personal information without further consent as permitted or required by PIPEDA section 7(3), including where disclosure is required to comply with a subpoena, warrant, court order, or other lawful order; required to comply with Canadian federal or provincial legislation (including the Criminal Code of Canada); necessary to protect the safety of any person from imminent harm; necessary to prevent or investigate fraud; or necessary to establish, exercise, or defend Routebook's legal rights.

Where permitted by law, we will attempt to notify you of legal demands for your personal information before complying.

5.5 Business Transfers

If Routebook is involved in a merger, acquisition, reorganization, bankruptcy, or asset sale, your personal information may be transferred as part of that transaction, in accordance with PIPEDA section 7(2)(b.1) (prospective business transactions).

5.6 With Your Consent

We may share your personal information for other purposes with your express prior consent.

6. Data Retention

We retain your personal information for as long as your account is active and for a period afterward, consistent with PIPEDA Principle 4.5.3.

You may request deletion of your personal information at any time (see Section 8). Some information may be retained longer if required by law or to resolve an active legal dispute.

7. Security

We implement commercially reasonable technical and organizational security measures to protect your personal information, consistent with PIPEDA Principle 4.7 and the sensitivity of the information held, including encryption of data in transit using TLS, encrypted storage of sensitive fields at rest, role-based access controls, and regular review of security practices.

No system is completely secure. We cannot guarantee that your personal information will never be accessed or compromised.

7.1 Breach Notification

In the event of a "breach of security safeguards" (as defined in PIPEDA section 2(1)) involving your personal information, Routebook will:

• Assess whether the breach creates a real risk of significant harm to any individual, applying the factors in PIPEDA section 10.1(8)
• Where there is a real risk of significant harm, notify affected individuals as soon as feasible in the manner required by PIPEDA section 10.1(3) and the Breach of Security Safeguards Regulations (SOR/2018-64)
• Report the breach to the Office of the Privacy Commissioner of Canada as required by PIPEDA section 10.1(1)
• Notify any organization or government institution that may be able to reduce the risk of harm, where PIPEDA permits
• Maintain a record of every breach of security safeguards for 24 months, as required by PIPEDA section 10.3

Where a breach also affects residents of British Columbia or Alberta, we will comply with the applicable notification requirements under the Provincial PIPAs.

8. Your Rights and Choices

The following rights are provided under PIPEDA and the Provincial PIPAs. To exercise any of them, contact us at [email protected]. We will respond within 30 days of receipt (which may be extended by an additional 30 days where the request is complex, in accordance with PIPEDA section 8(3)–(4)).

8.1 Right of Access

You have the right to be informed of the existence, use, and disclosure of your personal information and to be given access to it (PIPEDA Principle 4.9). On request, we will provide a summary of the personal information we hold about you, how it is used, and the third parties to which it has been disclosed. We may require you to verify your identity before responding.

8.2 Right of Correction

You have the right to challenge the accuracy and completeness of your personal information and have it amended as appropriate (PIPEDA Principle 4.9.5). You can update most profile information through the app settings; for information you cannot change through the app, email [email protected].

8.3 Right to Withdraw Consent

You may withdraw your consent to the collection, use, or disclosure of your personal information at any time, subject to legal or contractual restrictions and reasonable notice. Withdrawal of consent to information categories necessary to operate the Platform will result in termination of your account.

8.4 Right to Account Deletion

You may delete your account at any time through the app settings. We will delete or anonymize your personal information within 30 days, subject to the retention exceptions in Section 6.

8.5 Right to Complain to a Regulator

If you are not satisfied with our response to a privacy inquiry or complaint, you may contact the Office of the Privacy Commissioner of Canada at 1-800-282-1376 or at priv.gc.ca. Residents of British Columbia may contact the Office of the Information and Privacy Commissioner for British Columbia at oipc.bc.ca. Residents of Alberta may contact the Office of the Information and Privacy Commissioner of Alberta at oipc.ab.ca.

8.6 Marketing Communications

You may opt out of marketing emails via the "Unsubscribe" link in any marketing email. We comply with CASL — we send commercial electronic messages only with your express or implied consent, we identify ourselves in every message, and we provide an unsubscribe mechanism in every message that we honour within 10 business days. You may manage push notification preferences through your device settings. We may continue to send you transactional messages (e.g., message alerts, account security notices) regardless of marketing preferences.

8.7 Location

You may revoke location permissions at any time through your device settings. Disabling location access may limit certain features.

8.8 Biometric Information

As part of our identity-verification requirement (Section 2.3), you submit a government-issued identity document and a real-time selfie through Persona. Persona uses biometric identifiers derived from the selfie and the ID photograph — including facial-geometry data — to confirm that the person submitting the check is the person shown on the document.

• Purpose of collection: solely to verify your identity as a condition of using the Platform.
• Who receives the data: the images and biometric information are collected, stored, and processed exclusively by Persona, not by Routebook. Routebook receives only the outcome and the extracted printed fields.
• Retention: biometric identifiers are retained by Persona in accordance with Persona's own retention schedule. Routebook does not itself retain biometric data at any time.
• Destruction: upon your request through [email protected], or upon deletion of your account, Routebook will submit a redaction request to Persona for the biometric data associated with your verification session.
• No sale, no disclosure without consent: neither Routebook nor Persona sells, leases, trades, or otherwise profits from your biometric information. Neither will disclose your biometric information to any third party except with your written consent, to complete the verification transaction you initiated, if required by a valid subpoena, warrant, or court order, or as necessary to protect against fraud, abuse, or a violation of law.

This disclosure is provided consistent with PIPEDA's heightened sensitivity standard for biometric information and the Office of the Privacy Commissioner of Canada's guidance on biometric processing.

9. Children's Privacy

The Platform is not directed to children. Our minimum age requirement is 19 (see Terms of Service). We enforce this age requirement operationally: every user is required to complete Persona verification before posting a route or requesting a seat, and Persona extracts the date of birth from the ID document. Users whom Persona determines are under 19 are automatically rejected as ineligible and their submitted document images are redacted from Persona.

If we nonetheless discover we have collected information from a person under the age of digital consent in the applicable province, we will delete it promptly. If you believe a minor has provided personal information to us, contact us at [email protected].

10. Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes, we will notify you through the app or by email. Your continued use of the Platform after notice constitutes acceptance of the updated Policy.

11. Contact and Privacy Officer

Routebook has appointed a Privacy Officer responsible for ensuring compliance with PIPEDA. For privacy questions, requests, or concerns:

Privacy Officer
RouteBook LLC
[email protected]

This Privacy Policy was last updated on October 24, 2026.