Privacy Policy

Effective Date: 2023-03-01 

RideFlag Technologies Inc., a federal corporation in Canada, also doing business as “RideFlag” (the “Company”), collects certain information about you in the RideFlag mobile app (the “App”). The Company cares about your privacy, and this Privacy Policy describes our policies and procedures surrounding the collection and handling of any information we collect from you. 

Your use of the App constitutes an acceptance of this Privacy Policy and forms a legally binding contract between the Company and you. If you do not agree to the terms of this Privacy Policy, immediately discontinue use of the App and delete it from your mobile device. In addition, to revoke consent to the use of your information and to have your information removed from our database, contact us using the contact information listed at the end of this Privacy Policy, and your information will be deleted. 

You understand that by using the App, you consent to the collection, use, and disclosure of your personally identifiable information, your GPS location, and aggregate data as set forth in this Privacy Policy. 

Any capitalized words not expressly defined in this Privacy Policy have the meanings assigned to them in the Terms of Use Agreement of which this Privacy Policy forms an integral part. 

Collection of Information 

Information you provide 

The Company may collect and store any personal information you enter using our App or provide to us in some other manner. This includes your location id, your transponder id, your mobile phone number, and known participants. Your phone number and password are required to sign in to the App. You may also provide us your GPS location , and aggregate data as set forth in our Terms of Service, and to have your personally identifiable information collected, used, transferred to and processed within the United States. 

Information we collect 

The App collects two different kinds of information from you: 

Methods of Collection 
The App collects your information both actively and passively. Active data collection occurs when you enter your information when you are creating an account with the App. Passive data collection occurs without your affirmative consent by the App’s use of analytic and reporting technologies. 

The App actively collects your email address, password, phone number and transponder ID when you supply them by registering to use the App. These data items are considered PII because each of them could either: (i) be used individually to identify you or to contact you; or (ii) be used in combination with each other to access your account. 

The App passively collects certain anonymous information about your use of the App. Non-PII data is your phone operating system version information, the date and time of use of the I-680 Express Lanes, and mobile phone device. The App also passively collects your geographical location data if you have agreed to allow location access in the App settings. This collection will take place either while you are using the App or always depending on the setting you have selected. If you do not allow the App to collect your geographical location data, you will be unable to use the App.  
This list is not an exhaustive list of the types of passive non-PII we may collect; it merely provides examples. 

Information Collected Through Your Use of the App 
When you use the App, the Company collects information about you in the following categories: 

Statistical Information 
The App gathers statistical information automatically when you use it. 

User Profile 
The App collects the information you provide when you register for a RideFlag User account, including your name, your location id, your mobile phone number and password. 

Driver Profile 
The App collects information consisting of your toll transponder id as a Driver. 

“Occupancy Information” is the number of current passengers as provided by the App. This Occupancy Information is collected by using patented biometric analysis.  This Occupancy Information may be reported to the  Metropolitan Transportation Commission for the purposes of high-occupancy verification and/or high-occupancy incentives provided in return for Users’ participation in this program. Occupancy Information will be stored only on the Users’ mobile devices and not on any Company server nor in the cloud. 

Location Information 
“Location Information” is precise location data about the ride collected by the App. If you permit the App to access location services through the permission system used by your operating system, the Company may collect Location Information in the form of the precise location of your device when the App is running in the background or foreground. The Company may also derive your approximate location from your IP address. This Location Information may be reported to the Metropolitan Transportation Commission for the purposes of determining whether the registered vehicle likely traversed a specific location (such as a toll point) or a set of locations. 

Transaction Information 
The following data is stored on RideFlag’s server and deleted upon the closure of the App’s Pilot Program. The following data includes your name; phone number; password; email; license plate; Transponder ID; match probability; realness probability; date and time of trip; Express Lane entry and exit points; highway trip distance; other numerical information that is temporarily stored on the User’s smartphone device. Facial geometry measurements are only stored on the phone and are deleted at the end of each trip. 

Usage and Preference Information 
“Usage and Preference Information” consists of information the App collects about how you and other users interact with the App and your settings and preferences. The App may collect this Usage and Preference Information through the use of cookies, pixel tags, and similar technologies that create and maintain unique identifiers. 

Device Information 
The App may collect information about your mobile device, including the hardware model, operating system and version, software and file names and versions, preferred language, unique device identifier, serial number, device motion information, and mobile network information. 

Log Information 
When you interact with the App, it collects server logs, which may include information like the type of mobile device you are using, the device IP address, access dates and times, App features or pages viewed, App crashes, and other system activity. 

Use of Information 
The Company’s use of your Non-PII 
The Company may use your non-PII for the purposes of demographics and analytics. In addition, the Company may use this non-PII for the purpose of analyzing use patterns and trends with regard to the App. 

The Company’s use of your PII 

The Company may use your PII to: 
– Communicate with you via email, text message, or phone calls. You may opt out of these communications. 
– Perform internal operations, including, for example, to prevent fraud and abuse of the services, to troubleshoot software bugs, to conduct data analysis, testing and research; and to monitor and analyze usage and activity trends; 
– Personalize and improve the App, including to provide or recommend features and content. 
– Provide verified occupancy and Location Data to the Metropolitan Transportation Commission to enable the User to be issued with a high-occupancy verification and incentives 
– Transfer the information described in this Policy to process and store it in the United States. Validate verified occupancy and Location Data when you reach incentives levels. 

Use of aggregated information: Analytics and verification monitoring provided to third parties 

The Company may use anonymous, statistical or aggregated information (including anonymous location information), in a form that does not enable the identification of a specific User, to properly operate the App, to improve the quality of the App, to create new services and features, including customized services, to change or cancel existing content or services, and for further internal, commercial and statistical purposes. 

The Company may also use anonymous, statistical or aggregated information collected from the App, in a form that does not enable the identification of a specific user, by posting, disseminating, transmitting or otherwise communicating or making available such information to users of the App, departments of transportation, service providers, partners and any other third party. 

Location Information 
The Company requests permission for the App’s collection of Location Information per the permission system used by your mobile operating system. If you initially permit the collection of this Location Information, depending on your mobile device’s operating system, you may later be able to disable it by changing the location settings on your mobile device. However, this will limit your ability to use certain features of the App. Additionally, disabling the App’s collection of precise location from your device will not limit the App’s ability to collect your trip location information from a Driver’s device nor our ability to derive approximate location from your IP address. 

Third-Party Software Components 

Use of Google services 
The App incorporates the Google Maps API. By using the App, you are also accepting Google’s privacy policy (, which Google may amend from time to time. 

Other third-party software components 
The App may also incorporate various other third-party technologies to determine location, including IP address, GPS, and other sensors that will be used to provide the Company with information about nearby devices, such as Wi-Fi access points and cell towers. By using the App, you are also accepting the privacy policies of these third-party components. These third-party privacy policies may be requested from the Company and are made part of and incorporated by reference into this Privacy Policy. 

Access Rights 
The company will comply with the User’s requests regarding access, correction, and/or deletion of the PII we store in accordance with applicable law. 


Protection of Your Information 
The Company uses reasonable practices and technologies to safeguard your information against illegal intrusion and unauthorized access. No security measures are 100% reliable, however, so the Company cannot guarantee the security of your PII. 

You have the responsibility of protecting your username and password. You must contact the Company (using the contact information at the end of this Privacy Policy) if you have reason to believe that your account has been compromised. In addition, you agree that you will not share your username and password with anyone. 

The Company will never send you any communication (email or otherwise) asking for your username or password). If you receive any such communication that looks like it is from the Company, do not respond to the communication and immediately report the communication using the contact information at the end of this Privacy Policy. 

Third-Party Access to Your Information 
The Company will not share, lease, or sell your PII, but the Company may provide your information to the following third parties: 

Service providers 
The Company may disclose your PII to service providers who maintain the App. These trusted service providers will have access to your PII but may not use your PII for any purposes other than those to which they have been entrusted. The Company shall use reasonable efforts to ensure that these service providers hold your PII in confidence. In addition, the Company shall only disclose your PII to third parties that the Company believes, in good faith, follow acceptable privacy and security policies. 

Legal enforcement 
The Company may disclose your PII to investigate or enforce violations of our rights. The Company may also disclose your PII to protect the security of the App. In addition, the Company reserves the right to disclose your PII if the Company has a good faith belief that this disclosure is necessary to satisfy a legal process or an enforceable government request (such as a subpoena) or to be in compliance with any law or regulation. 

The Company may transfer your PII as part of a sale, merger, acquisition, or any other change of control. In addition, the Company reserves the right to transfer your PII to protect the Company’s legal rights in the unlikely event of a bankruptcy, reorganization, receivership, assignment, or any application of creditor’s rights. 

Correction or Removal of Your Information 
You may update and/or correct your information, including your PII, by contacting the Company (using the contact information at the end of this Privacy Policy) to request such modifications. The Company will require you to provide identification prior to the Company’s making such changes. The Company reserves the right to refuse any requests that are overly repetitive or that require unreasonable time or effort on the part of our technical team. In addition, the Company reserves the right to refuse any request that undermines the privacy rights of others. 

Policy With Regard to Children 
The Company will not knowingly collect any information from children under the age of thirteen (13) as is consistent with the Children’s Online Privacy Protection Act (“COPPA”) unless the parent or legal guardian of the child has provided that information to the App for the purposes of student challenges. If, as a parent or guardian, you discover your child under the age of thirteen has supplied the Company with PII or you wish to remove any PII that you have provided on behalf of your child, you may contact the Company, and we will remove your child’s information from our database. In this communication with us, please provide the username and password used by your child to enter their PII onto the App. 

Changes to this Privacy Policy 
The Company may change this Privacy Policy at any time, without prior notice to you, by posting a new version. The latest version will become effective on the date it is posted, which will be listed at the top of the policy as the Effective Date. Your continued use of the App is your acceptance of the new terms of the Privacy Policy. 

If the Company makes any modifications to this Privacy Policy that are materially less restrictive with regard to the Company’s use or disclosure of your PII (for example, if we decide to start selling your PII to third parties), the Company shall notify you and ask for your permission before continuing to use your PII under the new terms. 

Contact Information