PEARL TECHNOLOGIES LTD. PRIVACY POLICY
EFFECTIVE DATE: December 4, 2025
1. Introduction and Scope
Pearl Technologies Ltd. ("Pearl" or the "Company") is a technology provider that develops and operates the Pearl Technologies Driver Mobile Application and related software platform (the "Platform" or "Services"). This Privacy Policy sets out our policies and procedures regarding the collection, use, disclosure, and handling of Personal Information collected from users of our Platform.
By accessing, using, or interacting with the Platform, you agree to the terms of this Privacy Policy and consent to the collection, use, and disclosure of your Personal Information as described herein. If you do not agree, you must immediately cease all use of the Platform.
This Privacy Policy is designed to comply with Canada's Personal Information Protection and Electronic Documents Act ("PIPEDA") and other applicable privacy legislation.
1.1 Pearl's Role as Data Processor
Pearl often provides the Platform to enterprise clients (such as Carriers) under a commercial agreement. In these instances, Pearl may process data on behalf of the enterprise client, acting as a Data Processor or Service Provider, while the enterprise client acts as the Data Controller. The processing of data in this context is governed by the commercial agreement between Pearl and the enterprise client.
2. Personal Information We Collect
We collect various categories of information, which may include Personal Information, to provide, maintain, and improve the Platform.
| Category | Description |
|---|---|
| Account Information | Name, email address, phone number, and password (hashed). |
| Contact Information | Information provided when you communicate with us, such as support requests or inquiries. |
| Usage Data | Information about how you use the Platform, including features accessed, time spent, and interaction patterns. |
| Location Data | Real-time and historical GPS location data, including location data collected while the Application is running in the background, necessary for dispatch and trip tracking services. |
| Device/Browser Metadata | IP address, device type, operating system, browser type, device-level identifiers, and mobile network information. |
| AI Interaction Content | Any content, text, or data uploaded or input by users into features that utilize artificial intelligence or machine learning models. |
| Logs | Technical logs for debugging, analytics, security, and system troubleshooting. |
| Payment/Billing Information | Information required to process payments, subscriptions, and invoicing (e.g., billing address, payment card details handled by a third-party processor). |
| Authentication Data | Credentials used to verify your identity and access the Platform. |
| Communication History | Records of communications between you and Pearl, including customer support tickets. |
3. Purposes for Using Personal Information
Pearl uses the collected Personal Information for the following business and commercial purposes:
| Purpose | Description |
|---|---|
| Platform Provision & Maintenance | Providing, maintaining, and improving the Platform and Services, including load dispatch, trip data, and information display. |
| Authentication & Security | Authentication, fraud detection, preventing unauthorized access, and enhancing the security of the Platform. |
| Usage Analytics & Personalization | Analyzing usage patterns to understand user needs, personalize the user experience, and optimize Platform features. |
| System Improvement & Training | Training customer support and troubleshooting systems, and improving the underlying algorithms and models. |
| Communication | Communicating regarding updates, new features, service issues, and responding to support requests. |
| Contract & Legal Compliance | Compliance with contractual and legal obligations, including the enforcement of the EULA and acceptable use rules. |
| Financial Processing | Processing payments, subscriptions, and invoicing. |
3.1 Use of Data for System Improvement and AI Training
- Pearl may use de-identified or aggregated data to improve system performance, train algorithms, detect misuse, and enhance our products.
- Pearl does not use your identifiable Personal Information to train models unless you provide explicit consent or unless this is a necessary part of your commercial agreement with Pearl or your Carrier.
4. Consent and Legal Basis for Processing
Pearl processes Personal Information based on the following legal grounds:
- Consent: Consent is obtained when a user creates an account, uses the Platform, accepts the EULA, or interacts with Pearl's Services.
- Contractual Necessity: Processing is necessary to fulfill our contractual obligations to you or your Carrier (e.g., providing location data for dispatch services).
- Legitimate Interests: Processing is necessary for Pearl's legitimate business interests, such as security, fraud prevention, and Platform improvement.
Withdrawal of Consent: Users may withdraw consent except where the data is required to operate their account, fulfill contractual obligations, or for legal reasons.
Data Processor Role: If Pearl acts as a service provider to third-party customers, data processing may be based on contractual obligations with that third party rather than direct consent from the user.
5. Disclosure and Transfer of Personal Information
We may disclose Personal Information to the following categories of recipients:
- Your Carrier: We share data with your Carrier as necessary to provide the Services (e.g., location data for dispatch, trip data for payroll).
- Service Providers (Processors/Subprocessors): Third-party vendors, consultants, and other service providers who perform services on our behalf, such as cloud data storage vendors, hosting providers, and payment processors.
- Legal and Regulatory Authorities: When required by law, subpoena, or court order, or to protect the rights, property, or safety of Pearl, our users, or the public.
- Business Transfers: In connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
Pearl ensures, by contractual or other means, that all third parties protect the information and use it only for the purposes for which it was transferred.
5.1 Transportation Industry Data Sharing
In connection with your transportation services, we may also share data with:
- Shippers and Consignees: Delivery confirmation, proof of delivery, and estimated arrival times.
- Regulatory Authorities: Transport Canada, Ministry of Transportation Ontario (MTO), U.S. Department of Transportation (DOT), Federal Motor Carrier Safety Administration (FMCSA), and other transportation regulators upon lawful request.
- Insurance Providers: In connection with claims investigations or underwriting purposes, as authorized by your Carrier.
- Law Enforcement: In emergency situations involving threats to safety, or pursuant to valid legal process.
5.2 Cross-Border Data Transfers
- Your Personal Information may be transferred to, stored, and processed in countries outside of Canada, including the United States, where our servers, cloud service providers, or Carriers may be located. By using the Platform, you consent to such transfers. Pearl ensures appropriate safeguards are in place through contractual arrangements with service providers, including data processing agreements that require recipients to protect your information in accordance with this Privacy Policy.
- Please be aware that the privacy laws in these countries may differ from, and may not be as protective as, the laws in Canada. However, we take steps to ensure that your Personal Information receives an adequate level of protection in the jurisdictions in which we process it.
6. Cookies, Tracking Technologies, and Analytics
Pearl and its service providers use cookies, web beacons, SDKs, and similar tracking technologies to collect and use Personal Information about you.
| Type of Technology | Description |
|---|---|
| Cookies | Small data files stored on your device that help us recognize you and improve your experience. |
| Web Beacons/Pixels | Tiny graphics with a unique identifier used to track user movement and understand the effectiveness of our communications. |
| SDKs (Software Development Kits) | Code blocks embedded in the mobile Application to enable third-party services (e.g., analytics, crash reporting). |
| API Logs | Records of interactions with our servers used for security and debugging. |
6.1 Types of Cookies Used
- Essential Cookies: Necessary for the Platform to function and cannot be switched off.
- Analytics Cookies: Allow us to count visits and traffic sources using tools like Google Analytics and Mixpanel to measure and improve the performance of our Platform.
- Preference Cookies: Used to remember your settings and preferences (e.g., language).
- Advertising Cookies: Used to build a profile of your interests and show you relevant advertisements on other sites.
6.2 Managing Cookie Preferences
You can manage your cookie preferences through your browser settings. However, disabling essential cookies may affect the functionality of the Platform.
7. Data Security and Retention
Security: We use physical, organizational, and technological safeguards to protect Personal Information. This includes password protection, encryption, and access controls. We utilize secure, industry-standard cloud data storage vendors for all data storage.
Retention: Personal Information is retained for as long as necessary to fulfill the purposes outlined in this Privacy Policy, to maintain your account, or as required by applicable laws and regulations.
8. Your Rights and Individual Access
You have the right to access your own Personal Information held by Pearl. A request for access must be made in writing to the Chief Privacy Officer. Pearl will respond to a request for access within a reasonable timeframe.
9. U.S. State Privacy Law Considerations
If you are a resident of a U.S. state with comprehensive privacy legislation (e.g., California Consumer Privacy Act/California Privacy Rights Act - CCPA/CPRA, Virginia Consumer Data Protection Act, Colorado Privacy Act, etc.), you may have additional rights regarding the collection and use of your Personal Information. These rights may include:
- The right to know what Personal Information is being collected.
- The right to request deletion of your Personal Information.
- The right to opt-out of the sale or sharing of your Personal Information.
Pearl is committed to complying with all applicable U.S. state privacy laws. For specific requests related to these rights, please contact our Chief Privacy Officer.
10. Changes to This Privacy Policy
Pearl may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or for other operational reasons. We will notify you of material changes by:
- Posting the updated Privacy Policy on the Platform with a new "Effective Date".
- Sending you an email notification to the address associated with your account (for material changes); and/or
- Displaying an in-app notification when you next access the Platform.
Your continued use of the Platform after the effective date of any updated Privacy Policy constitutes your acceptance of the revised terms. We encourage you to review this Privacy Policy periodically.
11. Contact Information
Individuals may address any questions or concerns regarding Pearl's compliance with this Privacy Policy to the Chief Privacy Officer.
Chief Privacy Officer: Pearl Technologies Ltd. at legal@pearltechnologies.com
Pearl will investigate all complaints and will take appropriate measures, including amending its policies and procedures, if a complaint is found to be justified.
