Privacy Policy

Effective Date: August 21, 2025
Last Updated: August 21, 2025

Zugo (“Zugo,” “we,” “us,” or “our”) operates a referral marketplace that connects passengers with independent, third‑party drivers (collectively, the “Services”). This Privacy Policy describes the personal information we collect, how we use and disclose it, and your choices.

By accessing or using the Services, you acknowledge that you have read and understood this Privacy Policy.

0) Marketplace Model & Responsibilities (Important role clarification)

What Zugo is. Zugo is a referral platform and does not provide transportation services. We are not a transportation carrier and do not employ or control drivers. We facilitate referrals and communications between passengers and independent drivers.
Independent drivers. Drivers are independent businesses (e.g., sole proprietors or corporations). They are not employees, agents, partners, or joint venturers of Zugo. They may collect and handle personal information (e.g., necessary trip details) in their own right to provide transportation to you. Drivers are separately responsible for complying with applicable privacy laws and for their own privacy practices.
Our responsibility vs. drivers’ responsibility. Zugo is responsible for personal information it collects or controls to operate its marketplace and referrals. Drivers are responsible for personal information they collect or control in the course of providing transportation as independent businesses. To the extent permitted by law, Zugo is not responsible for drivers’ independent acts, omissions, or privacy practices.

1) Scope and Definitions

“Personal Information” means information about an identifiable individual, as defined under applicable Canadian privacy laws (including PIPEDA). This Policy applies to the Services offered in Canada; additional terms may apply where required by provincial law (e.g., Alberta PIPA, BC PIPA, Québec Law 25).

2) Personal Information We Collect

We collect personal information directly from you, automatically from your devices, and from third parties as described below.

A. Information you provide to us

Identity and Contact Data: name, email address, mobile number, and home/work locations you choose to save.
Account Credentials: username and password (hashed/salted).
Profile and Preferences: rider/driver preferences, saved locations, accessibility needs you choose to share.
Communications: messages sent through the website or our Services, customer support inquiries, survey responses.
Payment Data: billing address and limited payment instrument details (processed by PCI‑compliant payment processors; we do not store full card numbers).

B. Information collected automatically

Usage and Log Data: website activity, timestamps, pages or screens viewed, referring URLs, and system activity.
Device and Technical Data: IP address, device identifiers, browser type and version, operating system, and diagnostics.
Location Data: precise or approximate location when you enable location services, and trip telemetry (e.g., pickup/drop‑off points, route, distance).

C. Information from third parties

Payment Processors: limited payment confirmations to complete transactions.
Analytics/Attribution Partners: aggregated insights to evaluate Service performance.

3) How We Use Personal Information

We use personal information to:

Provide and operate the Services: create/manage accounts; facilitate referrals and related communications; provide notifications.
Safety and integrity: detect, prevent, and investigate fraud, abuse, and security incidents; enforce our Terms.
Communications: send transactional messages (e.g., confirmations, receipts, service and security alerts) and, where permitted, marketing communications.
Improvement and analytics: monitor quality, develop new features, conduct research and analytics, and troubleshoot.
Legal and compliance: meet legal, regulatory, tax, and reporting obligations and respond to lawful requests.

We collect, use, and disclose personal information only for purposes a reasonable person would consider appropriate in the circumstances and as permitted by law.

4) SMS Program and Consent (CASL)

Zugo offers SMS communications related to your account and referrals/service updates and—where permitted—promotional messages.

Consent & content: For commercial electronic messages (e.g., promotional SMS), we obtain required consent and include sender identification and a working unsubscribe mechanism.
Opt‑out: You may opt out at any time (reply STOP). For assistance, reply HELP or visit https://zugo.info.
Frequency & charges: Message frequency may vary. Message and data rates may apply.
Record of consent: We maintain records of opt‑in/opt‑out status for compliance.
No sharing of SMS consent: We do not share mobile numbers or SMS consent with third parties or affiliates for their own marketing.

5) How We Disclose Personal Information

We do not sell personal information. We disclose personal information only as described below:

Service Providers (Processors): to providers that support operations (e.g., cloud hosting, payments, analytics, customer support) under contractual safeguards.
Marketplace disclosures (rider–driver): to facilitate a referral we may disclose limited information between rider and driver (e.g., first name, pickup details). Drivers may also collect information directly from you and are responsible for their own privacy practices.
Business transactions: in connection with a merger, acquisition, financing, or sale of assets, subject to confidentiality and continued protections.
Legal, compliance, and safety: where required by law or to protect the rights, property, or safety of Zugo, users, or the public.

We do not disclose mobile numbers or SMS consent to third parties or affiliates for their own marketing.

6) International & Interprovincial Transfers

Some service providers may be located outside Canada (including the United States). Personal information processed in other jurisdictions may be subject to the laws of those jurisdictions. We implement contractual and technical safeguards appropriate to the sensitivity of the data. Where required (e.g., under Québec Law 25), we conduct assessments before communicating personal information outside Québec.

7) Retention

We retain personal information only for as long as necessary to fulfill the purposes described in this Policy, to comply with legal and regulatory obligations (including tax, audit, insurance, and breach‑record obligations), to resolve disputes, and to enforce agreements. Retention periods vary by data category and context.

8) Security

We employ administrative, technical, and physical safeguards designed to protect personal information against loss, theft, and unauthorized access, use, or disclosure. Safeguards include access controls, encryption in transit where appropriate, security monitoring, and staff training. No method of transmission or storage is completely secure.

9) Your Rights and Choices

Subject to applicable law, you may:

Access your personal information held by Zugo;
Request correction of inaccurate or incomplete information;
Withdraw consent for optional uses (e.g., marketing SMS/email) without affecting prior lawful processing;
Delete/deactivate your account or request deletion of certain information, subject to legal and operational requirements.

10) Cookies and Similar Technologies

We use cookies and similar technologies to operate the Services, remember settings, analyze usage, and measure performance. You can manage cookies through your browser or device settings; disabling certain cookies may affect functionality.

11) Automated Decision‑Making

We may use automated logic for limited functions (e.g., fraud/risk signals). Where required by law (e.g., in Québec), we will inform you when a decision is made exclusively through automated processing and provide information about the decision and your options to have it reviewed by a person.

12) Children’s Privacy

The Services are not directed to individuals under the age of 16. We do not knowingly collect personal information from children under 16. If you believe a child has provided personal information to us, contact us so we can take appropriate steps.

13) Contact and Privacy Inquiries

Privacy Officer – Zugo
Email: zugo.info@gmail.com
Mailing Address: 54 Twin Willow Cres, Brampton, ON L7A 1K1, Canada

If you have unresolved concerns, you may contact the Office of the Privacy Commissioner of Canada (OPC) or, where applicable, your provincial privacy regulator.

14) Breach Notification

If a breach of security safeguards creates a real risk of significant harm, Zugo will notify affected individuals and report to the appropriate regulator(s) as required and keep breach records as required by law.

Permanent URLs:

Appendix: Independent Drivers (informational)

Drivers are independent organizations for purposes of Canadian privacy law. They may collect and process personal information to provide transportation services directly to you (e.g., to contact you about a pickup). They determine their own purposes and means for that processing and must provide their own privacy notices as required. If your question relates to a driver’s own handling of your information, we may refer you to the driver’s privacy notice/contact.