ONroute is committed to maintaining the privacy and security of your personal information. This Privacy Policy describes how ONroute collects, uses, discloses and otherwise processes personal information.
Who is ONroute?
For the purposes of this Privacy Policy, “ONroute” (“we”, “us” or “our”) means HKSC Developments L.P. and HK Travel Centres L.P.
Each of the gas bars operated at the ONroute travel centres are operated by independent retailers. As independent businesses, these retailers are responsible under applicable laws for adopting their own privacy policies to protect your personal information.
What is personal information?
For the purposes of this Privacy Policy, personal information is any information about an identifiable individual. The types of personal information that ONroute may collect includes contact information like your name, email and physical addresses and phone numbers, payment information like credit and debit card information, as well as information about the specific products and services that you purchase in our travel centres.
When do we collect personal information?
General
We collect personal information about you to deliver the products and services you request, to promote products and services that we believe you may be interested in, and to help improve your experience at our travel centres.
We collect personal information from you both at our travel centres and online. We collet personal information when you:
- Purchase goods or services from us;
- Request customer service or contact us;
- Enroll or participate in, or conduct any transaction under, a loyalty or rewards program offered by us or one of our brand partners;
- Participate in a contest, sweepstake, promotion or survey conducted by us or on behalf of one of our brand partners;
- Visit our Website or use free Wi-Fi services at our travel centres;
- Engage with us on social media; and
- Apply for employment with us.
We typically collect personal information directly from you or through our interaction with you. However, we sometimes may obtain personal information about you from other sources. For example, we may collect personal information from third parties, such as: in connection with your use of a reward or loyalty program offered by us or one of our brand partners or other service providers; from an insurance provider or claims adjuster who manages the resolution of claims that may occur at our travel centres; and from government agencies and tribunals in connection with any complaints that may be brought.
Video Surveillance
In order to maintain the safety and security of our travel centres, certain areas of our travel centres use video surveillance. The information on our video surveillance systems that record your image are typically kept for a short period of time before they get overwritten with new information. They are not shared with third parties unless required in connection with an incident at one of our travel service centre locations.
Use of automatic data collection technologies
As you navigate through and interact with our website (www.onroute.ca) (the “Website”), we may use automatic data collection technologies, such as web beacons and cookies, to collect technical information about your visit to our Website, browsing actions and patterns.
Cookies are small text files that are placed on your device when you visit our Website. Cookies may automatically collect information about you, such as an identifier assigned to your device, your Internet Protocol address (IP address), time spent on our Website, web pages or websites visited and browsing habits. We use this information to help understand Website activity and improve our website. You may be able to use your browser settings to block cookies or to notify you before a cookie is set. If you block cookies you may not be able to use all of the features of our Website.
We may also work with third parties, like ad networks, online advertisers and social media platforms, so that we and they may serve you with advertising that is tailored to your inferred interests. These third parties may use cookies and similar tracking technologies for these purposes.
We use Google Analytics to collect information about your use of the Website, such as the features used and time spent on the Website, to help us better understand our users and improve our Website. You may learn more about the data practices of Google Analytics here: https://support.google.com/analytics/answer/6004245?hl=en-GB.
We also use certain Google Advertiser features including Demographics and Interest Reporting, Remarketing, and Google Display Network Impression Reporting. These features use third-party cookies and other tracking mechanisms and allow us to market our products to you through advertisements on other websites based on your past visits to our Website. You can opt out of these Google features in your ad settings: http://www.google.com/settings/ads/.
We use targeted advertising features provided by Facebook and Twitter. You can control targeted advertising on Facebook and Twitter through your privacy settings on these platforms. You may also be able to opt-out of targeted advertising on these platforms and other websites through the Digital Advertising Alliance of Canada’s Your Ad Choices opt-out tool here: https://youradchoices.ca/en/tools.
We use MailChimp to administer our email marketing subscriber lists and send emails to our subscribers. You may learn more about the data practices of MailChimp here: https://mailchimp.com/legal/privacy/
Wi-Fi
If you choose to use the free Wi-Fi service available at our travel centres, we automatically collect certain information about the device you use to connect to the service (such as MAC address, device type, device name, operating system, and geolocation information). We may also use cookies and similar tracking technologies to collect information about how you use the service, such as when and for how long you use the service, and information about the websites that you visit. We use this information to provide and improve the service, to better understand our customers and for tailored advertising. We may also share this information with advertisers and ad networks so that they can serve you with advertising based on your inferred interests. You may be able to use your browser settings to block cookies or to notify you before a cookie is set. If you block cookies you may not be able to use all of the features of the Wi-Fi Service.
Why do we collect personal information?
We use your personal information to offer and provide our products and services and to manage, maintain, and develop our operations. In particular, we collect personal information in order to:
- To fulfill your requests for products and services at our travel centres and communicate with you about these offerings;
- Protect the security and integrity of our Website, our Wi-Fi service, and our assets and travel centre locations;
- Administer surveys, sweepstakes, contests and promotions either directly or with our brand partners or service providers;
- Conduct analysis and evaluations to understand usage and trends to improve our Website, services, communications and operations;
- To understand your needs and preferences so that we can serve you with advertising that is tailored to your inferred interests;
- To interact with you on social media;
- Enable us to comply with applicable laws or regulatory processes and as otherwise permitted or required by law; and
- Any other reasonable purpose to which you consent.
To accomplish these purposes, we may combine personal and other information we collect, including information from third parties.
When do we disclose your personal information
We may disclose your personal information within the ONroute corporate family and our respective employees, contractors, consultants and service providers who require such information for the purposes described in this Privacy Policy, including to assist us with managing our relationship with you. For example, we may share your contact information with a branch manager to enable them to respond to any feedback provided via our general contact information page about a travel service centre location.
Your personal information may be disclosed:
- To third party advertising networks and advertisers to serve you with tailored advertising online;
- As permitted or required by applicable law or regulatory requirements;
- To comply with valid legal processes such as search warrants or court orders;
- During emergency situations or where necessary to protect the safety of a person or group of persons;
- In connection with a prospective or completed business transaction involving all or part of ONroute, whether by way of asset sale, stock sale or reorganization; and
- For any additional purposes for which we have obtained your consent to disclose your personal information.
Your personal information may be stored and processed by our service providers (including affiliates acting in this capacity) located outside Ontario, including in the United States. We require service providers to keep your information secure. In addition, service providers may not use or disclose personal information for any purpose other than providing the services on our behalf or as otherwise required by applicable law. By providing your personal information to us, you consent to our disclosure of this information to our service providers (and other third parties as described in this Privacy Policy), including those that may be located outside of Ontario or your jurisdiction of reference, for the purposes of processing your personal information on our behalf, providing services to us, operating our Website and for the other purposes described in this Privacy Policy.
Consent to treatment of personal information
We collect, use or disclose your personal information with your consent or as otherwise permitted or required by law. Depending on the sensitivity of the personal information, your consent may be implied, deemed or express. We may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required to do so by applicable law or regulatory requirements.
Security and retention
ONroute has implemented reasonable physical, organizational and technological security measures to safeguard the personal information in our custody or control. These include safeguards to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. Notwithstanding these safeguards, please be aware that no security measures can offer absolute security and it is possible that your personal information may be accessed or disclosed without authorization.
Personal information is retained as described in this Privacy Policy, and otherwise in accordance with our record retention policies. Our record retention periods are established taking into account requirements of privacy laws, the purposes for which the information was collected, legal and regulatory requirements to retain the information for minimum periods, limitation periods for taking legal action, and our business purposes.
Updates to your personal information
We want to keep your personal information up to date, accurate and relevant for its intended use. We rely on you to let us know if your address, telephone number or other information changes, so that we may provide you with the best possible service.
Access to your personal information
You can ask to access or correct the personal information that we have received from or possess about you. If you want to request access to or correction of your personal information, please contact our Privacy Office. Please note that any such communication must be in writing.
When requesting access to or correction of your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access or correct, as well as to search for and provide you with the personal information that we hold about you.
Please note that there are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices. In the event that we cannot provide you with access to your personal information, or make correction, we will endeavour to inform you of the reasons why, subject to any legal restrictions.
Covid-19 screening
In accordance with applicable law, ONroute collects certain information from individuals who dine at ONroute. This information may include symptoms and other information related to screening for COVID 19 as well as contact information, as determined by applicable government regulations. Personal Information relating to such purposes may be collected by ONroute or a third-party service provider either directly from you, or through our interaction with you. By using a dining area at ONroute, you are agreeing to the collection, use, and disclosure of this information in accordance with applicable law and the terms and Privacy Policies of ONroute and third-party service providers, as applicable.
Personal Information collected for the purposes mentioned in this section directly by ONroute will only be retained for a period of one month. While in our retention, it will be safeguarded in accordance with this Privacy Policy. Your Personal Information will only be used in the case of a potential COVID-19 exposure and may be disclosed in accordance with applicable law and only to those who require such information for the purposes described in this section.
As of the date of this Privacy Policy, ONroute is using the following third-party service provider: Canatrace. For information about Canatrace’s services and privacy, seehttps://canatrace.com/privacy-policy/.
Questions or concerns?
If you have any questions about this Privacy Policy or concerns about how we manage your personal information, please contact our General Counsel at the addresses set forth below:
ONroute Travel Centres
8 Prologis Blvd., Suite 402
Mississauga, Ontario L5W 0G9
Attention: General Counsel
If you are dissatisfied with our response, you may be entitled to make a written submission to the Privacy Commissioner.
Changes to this policy and application
This Privacy Policy is effective as of the Effective Date below. ONroute reserves the right to change this Privacy Policy at any time. We will take reasonable steps to advise you of any changes to this Privacy Policy, including by posting the revised policy on our Website. We recommend that you review this Privacy Policy from time to time to obtain the current version. You may contact us at the addresses set forth above in Questions or Concerns to obtain a current copy of this Privacy Policy.
Effective Date: June 11, 2021