TCONNECT PRIVACY POLICY

Rogers Transit Services Inc. (formerly BAI Communications Inc.) (“RTSI” / “we” / “us”) respects the privacy and personal electronic communication of the users of the RTSI Services

This Privacy Policy describes our policy for the collection, use, and disclosure of your Personal Information retained by us.

What does this Privacy Policy cover?

This Privacy Policy applies to Personal Information, which is information that can identify an individual.

Information that we have about you may be de-identified or anonymized for internal purposes, such as to identify trends, manage our business, develop statistical information, understand how services are performing, develop relevant products, services or offers, and manage business risks such as preventing and detecting fraud.

When we de-identify or anonymize information we remove any identifying information. Once such information has been removed it is no longer personal information. This information may also be aggregated with other information. Such information is not subject to this Privacy Policy.

We use industry accepted best practices and methods for de-identification and anonymization to prevent the intentional re-identification of the information.

What services does this Privacy Policy apply to?

RTSI Services covered by this Privacy Policy include the following:

1. the Internet services operated by RTSI, commonly known as “TCONNECT WiFi”
2. TCONNECT WiFi related captive portal and website(s) (collectively, “Site”) and
3. all software developed and made available in connection with any of the foregoing.

How is your consent obtained?

We collect information about your directly from your use of the RTSI Services.

By using the RTSI Services you are expressly consenting to the Terms of Service and this Privacy Policy. You are also agreeing to our use of your Personal Information in accordance with this Privacy Policy.

What Personal Information do we collect?

We collect Personal Information about you and your device using the RTSI Services. The type of information varies, depending how you interact with the RTSI Services, and includes cookies, MAC (Media Access Controller) addresses, or device IDs.

If you contact us for questions or concerns related to this service we will collected any Personal Information you provide us such as your name, address, telephone number, and/or email.

Anonymized network statistics is also collected and used through your interaction with the RTSI Services. This includes device and usage information, location information, the amount, and types of data you transfer, how you connect, how long you are connected, the services you use, and the advertisements you see and interact with while using the RTSI Services.

How do we use the Personal Information we collect?

To manage our business:

• We use information about you collected from the use of RTSI Services to manage, monitor, optimize and ensure the integrity of the services
• We use usage statistics, load factors, incidents, feedback, and fair use monitoring to make technical improvements to the network and ensure that the service is operating for the benefit of all users
• We use information to help improve the content and functionality of the RTSI Services and enable features.

To provide you with additional value and personalize your experience:

• We use information about you to create personalized content, or to tailor services and advertising that may be of more interest to you, based on inferences derived from your use of the service.

For our own statistical purposes:

• We will use anonymized usage statistics and device information such as usage patterns, travel patterns and website page views for internal purposes, including network management and service improvement.

To detect potential fraud, abuse, unlawful use, and other violations of our Terms of Service:

• If required, Personal Information will be used to maintain the integrity and security of the RTSI Services and protect other users.

To communicate with you:

• Your Personal Information will be used if you contact us for customer support to respond to your questions or resolve your concerns.

To comply with the law:

• If required or permitted by law, we will use your Personal Information to fulfill our legal and regulatory obligations.

Where is my information stored?

Personal Information may be stored or processed in or outside Canada. The information will be protected with appropriate safeguards and standards that adhere to applicable Canadian privacy laws but may also be subject to the laws of the jurisdiction where it is held.

How long does RTSI keep my information?

We will keep your Personal Information for as long as it remains necessary for the identified purpose or as required by law. The length of time it is kept will vary depending upon the information and the purpose why it was collected.

What is the RTSI Services policy regarding links to other sites?

You should be aware that while you are using the RTSI Services, you will access other sites that are beyond our control. We cannot control the privacy practices of these websites and recommend your read the privacy policy of the website you link to before you submit any of your Personal Information. The links from the RTSI Services do not imply that we endorse or have reviewed such third-party sites.

Opting Out

We provide of the following options to for you to control how your Personal Information is used by the RTSI Services:

• Disable cookies. To remove consent for the use of cookies by us and our partners, it is possible to turn them off in your web browser preferences. By disabling cookies, your web surfing experience will be less than optimal. Please refer to your web browser’s settings to manage website cookies.
• Use your device’s settings to opt out of targeted advertising. You will still continue to see ads, but they will only be less relevant to you, as they will not be based on your selections, preferences, or browsing habits.
• Use AdChoices to opt out of targeted advertising. Our advertising partners are member of the AdChoices Digital Advertising Alliances, and they respect the preferences you declare using AdChoices controls. You can select the types of ads you wish to see using the controls offered on the AdChoices website or using a downloadable mobile app. You will continue to see ads, but they will only be less relevant to you, as they will not be based on your selections, preferences, or browsing habits. To learn more about AdChoices visit http://youradchoices.com/learn and you can configure your ad choices by visiting http://youradchoices.com/control.

If you have questions

If you have any questions about this Privacy Policy, please contact us at privacy@rci.rogers.com or by regular mail at Rogers Transit Services Inc. c/o Rogers Communications Inc., Attn: Privacy Officer, 333 Bloor St. East, Toronto, Ontario, M4W 1G9.