Privacy Policy

SMART START PRIVACY POLICY

Last Updated: September 23, 2026

Smart Start Canada ULC  (“Smart Start”) is a provider of alcohol monitoring services through its Ignition Interlock Device Programs across Canada (the “Services”) and is committed to respecting the privacy of our clients, employees, and stakeholders, and protecting the personal information we collect.

This Privacy Policy applies to our business operations and explains how we collect, use, disclose, and protect personal information while providing Services. This Privacy Policy is to be read in conjunction with any other privacy notices or addendums that have been accepted by the clients of Smart Start.

Where we collect personal information while providing Services, we will obtain your consent as described in this Privacy Policy. We comply with relevant federal, provincial, and territorial privacy laws including the Personal Information Protection and Electronic Documents Act of Canada.

We may update this Privacy Policy from time to time. Updated versions of this Privacy Policy will be posted on our website located at www.smartstartcanada.ca. Where we materially change how we collect, use, disclose, or retain personal information in a way that requires it, we will take reasonable steps to notify affected individuals in advance and will obtain any additional consent required by law.

1. Information We Collect

In this Privacy Policy, “personal information” means information about an identifiable individual. Personal information may include names, age, sex, personal contact information, and other contextual information that may identify an individual. Personal information does not include aggregated or anonymized information.

We collect personal information that you provide while using our products and services to the extent necessary to provide and administer our Services. Personal information that we collect may include the following:

  • Name and contact details, including email, address, mailing address, and phone number.
  • Employment information (e.g., employer name and length of employment).
  • Driver’s license number.
  • Court orders and as they relate to a client’s enrollment in the Ignition Interlock Device Program.
  • Ignition Interlock Device blood alcohol measurements and other compliance information (failed or missed testing, tampering and circumvention).
  • Payment information (e.g., bank account and credit card details).
  • Records of communication and dealings including contact forms, emails, telephone, and other communications during the course of Smart Start’s provision of the Services; and
  • Personal employee information of potential, current, or former employees.

We collect personal information from the individual to whom the information belongs to unless it is unreasonable or impractical to do so and/or collection from a third party is permitted by law. Collection may happen in several ways including through verbal and written communications with our personnel, forms that you submit to us, and your use of our website as detailed further below.

If you choose to provide us with personal information about another person, you must only do so if permitted by law or that person has consented to you doing so and to us collecting, using, and disclosing their information.

1. Online services

When using our online services, such as our website, our computer systems may automatically collect information about you and how you use our online services. We may collect information such as:

  • Usernames and passwords that you create to access our platforms.
  • Which pages you visit on our website;
  • Device information, such as the model and ID of the device you use;
  • Server log information, such as details of how you used our platforms, IP address, hardware settings, browser type, browser language, the date and time of your use and referral URL;
  • Information that may uniquely identify your browser or your account; and
  • Location information.

If you visit our website and our platforms, we may collect information on your use of the website, such as pages visited, links clicked, text entered, as well as information more commonly collected such as the referring URL, browser, device, operating system, and Internet Protocol (“IP”) address. We may use publicly available sources to approximate your geographic region and Internet Service Provider based on your IP address.

We may use your IP address or domain name for internal traffic monitoring and capacity management purposes or to otherwise administer our website and our platforms. No personal information is obtained, rather the patterns and usage of our website and our platforms may be tracked for the purposes of providing improved service and content based on aggregate or statistical review of user traffic patterns.

We may use various technologies to collect and store information, including cookies, pixel tags, local storage, such as browser web storage or application data caches, databases, and server logs. These technologies help us track your usage and remember your preferences. For example, cookies are small files that store information on your computer browser, mobile phone or other device. Cookies enable the entity that placed the cookie to recognize you across different websites, services, devices, and browsing sessions. If you choose, you can set your browser to reject cookies or you can manually delete individual cookies or all the cookies on your computer by following your browser’s help file directions. Turning off cookies may also disable functions of many websites you visit. You can disable cookies, but our platforms may not work as intended if you do so.

Our website and our platforms may contain links to other websites. We are not responsible for the privacy practices or the content of other websites. The privacy practices applicable to other websites may differ substantially from ours. Please read the privacy policy of any other websites you visit before using them. We do not accept responsibility for the content or practices of websites operated by third parties that are linked from or that link to our websites.

We collect, use, and disclose personal information with your consent, except where otherwise permitted or required by law. You may withdraw your consent at any time, subject to legal or contractual restrictions (such as regulatory record-retention obligations or outstanding Service commitments) and reasonable notice, although this may affect our ability to provide certain Services.

3. How We Use Personal Information

We use the personal information we collect from clients where necessary to provide information, services, or products requested or purchased, and to allow clients to interact with us and our website. This may include sending clients emails from time to time. These emails contain information requested by clients such as notices of updates to our products.

We may use personal information collected for multiple other purposes within our organization including:

  • Providing our products and services, specifically to administer our Ignition Interlock Device Programs;
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  • Monitoring client compliance with the Ignition Interlock Device Programs;
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  • Responding to inquiries and providing client support;
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  • Processing payments;
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  • Protecting against fraud, misuse, or unauthorized activity;
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  • Managing our employment relationships;
  • Administering our payroll and employment benefits;
  • Fulfill contractual and regulatory obligations;

Maintain the security and integrity of our systems; and Complying with legal and regulatory requirements.

 4. Disclosure of Personal Information

We do not disclose personal information for purposes other than those identified at the time of collection without obtaining further consent, except as permitted or required by law. We are responsible for personal information under our control, including information transferred to service providers (meaning third parties that process personal information on our behalf and under our instructions).

We may disclose personal information in the following circumstances:

  • To monitoring authorities to report on client compliance with the Ignition Interlock Device Programs;
  • To service providers or contractors who assist us with conducting our business operations where necessary to provide and administer our Services;
  • To comply with a subpoena, warrant, or court order;
  • To investigate fraud, security issues, or other unlawful activity;
  • In connection with a sale, merger, financing, reorganization, or other business transactions, or the potential for one, subject to appropriate confidentiality protections;
  • In emergency situations where the life, health or security of an individual is at issue;
  • Fulfill contractual and regulatory obligations;
  • Maintain the security and integrity of our systems;
  • To manage our employment relationships;
  • To administer our payroll and employment benefits;
  • Where you have provided consent or as otherwise directed by you; and
  • For any other reason as permitted or required by law.

5. Minors

We do not knowingly collect, use, or disclose personal information from individuals under the age of eighteen without appropriate parent or guardian consent where permitted or required by law. If we learn that we have collected personal information from a minor without required consent, we will take reasonable steps to delete or de-identify that information, unless retention is permitted or required by law.

6. Third Party Processing and Outside Canada Transfers

Information collected may be processed by third party service providers. These providers may process or store information outside Canada, including in the United States or other jurisdictions where they operate, for purposes of such service delivery. As a result, personal information may become subject to the laws of those jurisdictions. In such cases, we take appropriate measures to protect personal information in accordance with applicable privacy laws. You may contact our Privacy Officer as identified below if you have any questions regarding third party processing and whether your personal information is stored outside of Canada.

7. Retention

We retain personal information for as long as reasonably necessary to fulfill the purposes for which it was collected, to manage our relationship with you, to meet legal, regulatory, accounting, professional, insurance, and business requirements, and to resolve disputes or enforce agreements. When personal information is no longer required, we will securely destroy, erase, or anonymize it using reasonable measures appropriate to the sensitivity of the information, including secure destruction of paper records and secure deletion of electronic records where applicable.

8. Security

We take reasonable steps to protect personal information collected in connection with our services from unauthorized access, use, disclosure, alteration, or loss. We will implement safeguards appropriate to the level of sensitivity, which may include physical, technical, and administrative safeguards; role-based and minimum-necessary access; individual user accounts and secure passwords where available; restrictions on shared administrative accounts; personnel confidentiality obligations; secure or encrypted communications where appropriate; access monitoring or audits; and procedures for reporting and addressing suspected incidents. However, no organization can operate in an absolutely secure system and while we will make a reasonable effort to safeguard your personal information, unauthorized access, use, disclosure, loss, or destruction cannot be fully mitigated.

Please note that e-mail and other electronic communications sent over the internet are at risk of being subject to viewing, alteration or copying by other parties. Smart Start Canada is not responsible for the security of communications sent to us via the email and the internet.

9. Access, Correction, Complaints, and Privacy Rights

We take reasonable steps to ensure that the personal information we hold about you is accurate, complete, and up to date.

Subject to limited exceptions under applicable law, you may request access to personal information we hold about you and request correction of inaccurate or incomplete personal information. We may ask for clarification with respect to the personal information that you are seeking to access or correct. We will respond to your access or correction request in accordance with applicable laws. Depending on the size and nature of the access request, we may charge a reasonable fee to process your request.

In circumstances where we cannot provide you with access to your information or make corrections, we will provide you with a reason for the refusal and inform you of mechanisms to make a complaint about the refusal before an appropriate privacy regulator.

Questions, access or correction requests, complaints, and escalations may be directed to our Privacy Officer using the contact information below. We will respond within the time required by applicable law. If you are not satisfied with our response, you may contact the Office of the Information and Privacy Commissioner of the applicable jurisdiction.

10. Privacy Breach Response

If we become aware of suspected or confirmed unauthorized access, use, disclosure, loss, or destruction of your personal information, we will take reasonable steps to contain, investigate, document, and remediate the incident. The Privacy Officer will oversee or support the investigation, take or recommend corrective action, and coordinate required follow-up. Where the incident creates a real risk of significant harm, or where notification is otherwise required by federal provincial, territorial, or other applicable law, we will notify affected individuals, or other regulators or organizations without unreasonable delay and in any event within the time required by applicable law, and we will keep records of reportable breaches as required by law.

11. Electronic Communications (Anti-Spam)

Where we send commercial electronic messages, such as newsletters, promotions, or marketing communications, we do so in accordance with Canada’s Anti-Spam Legislation. We will send such messages with your express or implied consent as permitted by law, will clearly identify ourselves and provide our contact information, and will include an unsubscribe mechanism in each message. You may withdraw your consent to receive commercial electronic messages at any time, and we will give effect to that request within the time required by law. Transactional, service-related, and legally required communications may continue to be sent regardless of your marketing preferences.

12. PRIVACY OFFICER Contact Information

If you have any questions about this Privacy Policy, your privacy rights, out-of-country handling of personal information, or our privacy practices, please contact our Privacy Officer:

Coni Crenshaw

privacy@smartstartcanada.ca

Director of Compliance and Privacy officer

Unit 120, 2899 Broadmoor Blvd

Sherwood Park, AB T8H 1B5