Tolling Privacy Policy
BNA O&M General Partnership (“BNA O&M”) operates and manages the Gordie Howe International Bridge and its Tolling Infrastructure on behalf of the Windsor-Detroit Bridge Authority (“WDBA”). The “Tolling Infrastructure” includes the electronic toll collection system located at the Gordie Howe International Bridge at the port of entry in Windsor, Ontario, Canada, together with all associated hardware, software and supporting communications required or necessary to perform tolling operations.
The purpose of this Privacy Policy is to describe how BNA O&M, acting on behalf of the WDBA, collects, uses, discloses and protects the Personal Information of the users of the Gordie Howe International Bridge and Tolling Infrastructure, and to explain how users can exercise their rights in respect of this Personal Information.
As BNA O&M operates and manages the Gordie Howe International Bridge and its Tolling Infrastructure on behalf of the WDBA, any Personal Information collected in connection with these activities is under the control of the WDBA and will be managed in accordance with and is subject to the Privacy Act.
I. WHAT IS PERSONAL INFORMATION?
For the purposes of this policy, “Personal Information” means any information about an identifiable individual. An individual will be considered identifiable where the information, alone or with other information that is reasonably available, can be used to identify that individual.
II. PURPOSES OF COLLECTING, USING, AND DISCLOSING PERSONAL INFORMATION
BNA O&M collects Personal Information to render services related to customers’ use of the Gordie Howe International Bridge and the Tolling Infrastructure, to administer a customer’s account, to provide and improve customer service, to enhance users’ experience of the website, improve the website and site features, and to contact registered toll account customers.
Summarized below are the main reasons BNA O&M collects Personal Information, the types of information involved, their sources, who BNA O&M may share it with, and customer choices with respect to their Personal Information.
A. Tolling Business Activities
- Purposes
BNA O&M collects customers’ Personal Information for the following purposes:
a. managing and operating the Gordie Howe International Bridge and the Tolling Infrastructure (e.g., registration of accounts, delivery of transponders, enforcing toll, processing and administration of fees).
b. maintaining and providing products and services for customers, such as loyalty program and mobile application.
c. carrying out billing and account management activities, including:
i. payment processing and collection activities
ii. evaluating creditworthiness
iii. providing advice or information on billing and payment options, managing discounts and closing accounts.
d. handling specific customer concerns or disputes.
e. data analytics, internal training or testing related to the above purposes.
f. for information security and other security purposes.
2. Information that BNA O&M Collects
In connection with the tolling business activities identified above, BNA O&M collects Personal Information.
a. when a customer opens or registers an account, including
i. name, mailing address, phone number, e-mail address
ii. financial information like credit card or banking information and credit history
iii. vehicle information like make, model, year, colour; licence plate number; and transponder identification number, if any.
b. in relation to the administration of transponders issued to customers,
i. account number
ii. vehicle information and transponder identifier and information
iii. mailing and shipping address, payment method and correspondence.
c. when customers use the Gordie Howe International Bridge and the Tolling Infrastructure,
i. trip details on the Gordie Howe International Bridge, including camera images of front and rear licence plates.
ii. data generated through the Tolling Infrastructure’s toll collection process that reveals the date, time, location or direction of travel by customer.
iii. audio and video surveillance of public spaces.
d. information that customers provide though voluntary submissions such as queries posted in the “Contact Us” section and information they provide when they register for services on the site, respond to a survey, or fill out a form.
e. customers’ Internet Protocol (IP) addresses may be captured in firewall and webserver logs. This forms part of BNA O&M’s security and threat mitigation processes to identify and prevent potentially malicious attackers. The IP addresses are not correlated with any other web analytic information and any digital marker or web analytic information about individual users, unless an attempt to damage the site has been detected.
- Sources of Information
a. customers, when they open an account, travel on the Gordie Howe International Bridge and the port of entries, communicate with and use products or services offered by BNA O&M or WDBA.
b. third-party partners or service providers for credit assessment or collections purposes, such as credit reporting agencies and collection agencies.
- Sharing of Personal Information
In connection with the tolling business activities, BNA O&M may share Personal Information with the following:
a. WDBA, government or motor transport agencies, such as the Ontario Ministry of Transportation (“MTO”) and Michigan Department of Transportation (“MDOT”), or third parties responsible for managing driver data.
b. third-party partners or service providers as part of credit assessment and collection activities, including government agencies, credit reporting agencies, and collection agencies.
c. other service providers that support tolling business activities, including quality assurance specialists, invoice and payment processors, and consultants.
B. Marketing and Promotions
- Purposes
BNA O&M collects Personal Information for marketing and promoting travel on the Gordie Howe International Bridge and use of products and services to actual and potential customers, including the use of Breakaway Account, mobile app, paperless billing, and transponders.
BNA O&M may also conduct data analytics, internal training, or testing related to these purposes.
- Information that BNA O&M Collects
In addition to the types of Personal Information used for tolling business activities listed above, BNA O&M may also collect and use:
a. individual feedback, shared experiences, opinions, and preferences.
b. mobile app data (see Section VIII, Breakaway Account and the mobile app).
c. web data about customers (see Section III, Manner of Collecting Information, Cookies and Other Web Data).
3. Sources of Information
In addition to the sources identified above, BNA O&M may also collect Personal Information from:
a. existing customers or potential customers engaging with BNA O&M or responding to its or WDBA’s marketing campaigns or participating in corporate-sponsored events.
b. the mobile app if customers download, install and use the app (geolocation, travel, and route information are only collected if customers expressly agree through their in-app privacy settings).
c. third-party direct marketing or mail vendors.
- Sharing of Personal Information
BNA O&M may share Personal Information with WDBA, and with third-party service providers carrying out marketing and promotions, such as marketing and communications agencies, digital or social media marketing and analytics vendors, and consulting firms.
- Customer Choice
Customers can opt out of the use of their Personal Information for marketing purposes by contacting BNA O&M using the information in Section IX (BNA O&M Accountability).
Customers can also unsubscribe from emails or other messages from BNA O&M through the Breakaway Account of mobile app and website.
C. Security, Legal and Compliance
- Purposes
BNA O&M likewise collects Personal Information for the purpose of satisfying security, legal, and compliance related activities, such as:
a. during an emergency where someone’s life, health or security is at risk.
b. responding to a lawful order of a court, regulatory agency or government tribunal.
c. preventing, detecting, or investigating illegal or harmful activity occurring at the Gordie Howe International Bridge or in connection with the Tolling Infrastructure or BNA O&M’s operations (including addressing toll evasion, property damage, fraud, or threats to the safety or security of individuals, data, or other assets).
d. asserting legal rights, such as defending claims and pursuing available remedies.
e. complying with applicable laws, rules, regulations, policies and other requirements or legal obligations, including responding to authorized audits of the company.
BNA O&M may also conduct data analytics, internal training, or testing related to these purposes.
- Information that BNA O&M Collects
Any of the types of Personal Information identified above may be necessary to satisfy security, legal, and compliance related activities.
- Sources of Information
The sources of Personal Information could potentially include any of the sources identified above.
- Sharing of Personal Information
BNA O&M may share Personal Information with WDBA, government or public motor transport agencies like the MTO, MDOT, law enforcement agencies, and third-party service providers, such as security firms, law firms, auditors, and consultants.
- Customer Choice
Most uses of Personal Information under this subsection will not be optional. If customers have any concerns, refer to Section XII (Contacting BNA O&M) for information about how customers can contact BNA O&M.
III. Cookies and other web data
A. The Use of Cookies
BNA O&M uses certain technologies and tools on the website (like cookies) and the mobile app to compile aggregate data about site traffic and site interaction, save customer preferences to provide better site experience, services and future content based on customers’ interests, and for tailored marketing purposes
Cookies and IP addresses
- first-party cookies sent directly from this website: may be used to customize content, track customers’ website preferences, gather the website’s total audience size and traffic, and improve website functionality and content.
- third-party cookies sent from authorized third parties: may allow sharing across social media services, provide targeted ads on external sites, and track customer preferences while using third-party services.
- web beacons and similar tools like clear GIFs, pixels, and coded URLs: may be used to determine which on-line ads customers have viewed, track if a promotional email was viewed or if its links were clicked; and support remarketing for ads across websites based on browsing interests.
BNA O&M only access cookies sent to customers’ devices, and customers may limit or disable cookie use through web browser settings. Customers may also choose not to click on links embedded in marketing emails. If customers choose to turn off all cookies via browser settings, this may cause web services to not function properly. However, customers may still purchase services by telephone or by contacting BNA O&M’s customer service.
BNA O&M also collects customers’ IP addresses to help estimate the total number of web visitors from various regions. An IP address is automatically sent by the customer’s computer web browser each time a web page is requested for viewing and this IP address is logged on to BNA O&M’s servers.
B. Google Analytics
BNA O&M uses a tool called Google Analytics on the website. Google Analytics uses the data collected through cookies to track the use of the website, prepare reports, and share them with other Google services. Advertising identifiers for mobile devices (such as Android and iOS Advertising Identifiers) are also collected. Google may use the data collected on the websites to contextualize and personalize the ads of its own advertising network.
For more information on how Google uses this data and how to control the information collected by websites, click here. Customers can also opt out of Google Analytics by visiting Google Analytics Opt-out.
C. Third party providers
BNA O&M may engage third-party service providers in better understanding site visitors and help improve services. They are not permitted to use information collected on behalf of BNA O&M except for this purpose.
IV. CROSS-BORDER TRANSFERS
In most cases, customers’ Personal Information is used, disclosed, and retained in Canada. In some situations, however, BNA O&M may disclose Personal Information outside of Canada (such as in the US) to achieve one or more identified legal purposes.
Personal Information in another jurisdiction may be accessed by the courts, law enforcement and national security authorities, and are subject to the laws of the other jurisdiction. BNA O&M will try to limit such disclosure, but where disclosure is required, BNA O&M will take steps designed to ensure that there is a comparable level of protection over customers’ Personal Information.
V. AUTHORITY AND CUSTOMER CONSENT
BNA O&M will collect, use, and disclose Personal Information under WDBA’s authority under the Privacy Act, with customer consent, and as otherwise permitted or required by law.
Customers’ consent can be express (written or verbal) or implied (through their action or inaction). Where BNA O&M relies on customers’ consent, BNA O&M will generally request express consent when it collects more sensitive Personal Information such as if BNA O&M needs financial information to assess customers’ registration or application to open an account.
BNA O&M may rely on customers’ implied consent if the purpose or consequence of collection is reasonably expected. For instance, when customers travel through the Gordie Howe International Bridge, the ports of entry, and its Tolling Infrastructure, they should reasonably expect that BNA O&M will collect and use their contact, vehicle, trip details and related information to send them a bill.
VI. ACCESSING AND UPDATING PERSONAL INFORMATION
Customers may make requests regarding access to their Personal Information. Upon written request (by mail or email only), and after verifying customer identity, BNA O&M will provide customers access to their Personal Information as required by law. Customers may also make Privacy Act requests through the official Government of Canada website.
BNA O&M will use reasonable efforts to make sure that customer Personal Information is up to date. However, customers are expected to notify BNA O&M if a change or correction is needed. Customers can make certain updates through Breakaway Account or the mobile app, as applicable, or by contacting BNA O&M by live chat, e-mail, or phone. While certain laws require customers to notify relevant government agencies (such as MTO) of a change in address within days of moving, these agencies do not automatically update BNA O&M. Customers are required to let BNA O&M know if they have moved and changed address.
VII. ANONYMIZED INFORMATION
BNA O&M may use Personal Information to generate anonymized data, which can be used and disclosed for any purpose, subject to applicable laws. Anonymized data cannot reasonably be used to infer information about customers or otherwise be linked to individuals.
VIII. BREAKAWAY ACCOUNT, THE MOBILE APP AND LOCATION SERVICES
The customers’ use of Breakaway Account is subject to the Breakaway Account Terms and Conditions.
BNA O&M will restrict access to a customer’s Breakaway Account information to the customer and to those persons authorized by the customer. If a customer initiates sharing a specific billing account within Breakaway Account via the web or the mobile app, those with whom it was shared may make payments and view details of that account, including historical or real-time trip details. The customer may revoke sharing at any time.
Personal Information collected by the app, when collected, or its uses depends on the privacy settings customers select on their mobile devices and is collected for the purposes set out elsewhere in this privacy policy. Personal Information that can be collected on the app include:
- vehicle geolocation, travel, or route information.
- mobile device ID.
- information about the device, browser, app use, and settings, such as notification and location options the customers have selected.
Customers can change settings in the mobile app at any time. If customers choose to disable or limit location services, certain app services may, however, be negatively impacted. Please refer to Section V (Customer Consent) for information about stopping the collection or use of Personal Information collected by the app.
Google & Location Services
The mobile application services are used to identify start and end points while determining route information. The user maintains control of location services by controlling their browser and mobile settings at any time. Users may opt-in or out of the use of their location at any time. Location services are only used to provide route information and/or relevant audio and visual alerts to the user. At no time does BNA O&M collect or store active route information. Please refer to Google’s Privacy Policy for further information on this service.
IX. CHANGES TO THE PRIVACY POLICY
Customers will be notified of material changes to this Privacy Policy through updates posted on this page, banner or pop-up notice, or email updates.
X. CONTACTING BNA O&M
If customers have any questions about this Privacy Policy or wish to exercise their rights under the Privacy Act with respect to their Personal Information, please contact BNA O&M at [email protected].