Privacy Policy

WestCoast GPS Tracking Ltd Privacy Policy

Last Updated: June 8, 2026

WestCoast GPS (“WestCoast,” “we,” “us,” or “our”) respects the privacy of individuals whose personal information we collect, use, disclose, or otherwise process in connection with our business. This Privacy Policy describes how WestCoast handles personal information in connection with our websites, applications, dashboards, interfaces, APIs (application programming interfaces), customer support, sales and marketing activities, and the fleet telematics solutions, software, reports, alerts, tools, data feeds, and related services that we make available (collectively, the “Services”).

This Privacy Policy is intended to be read together with WestCoast’s Online Terms and Conditions (to be added to our website next week) and any applicable order, subscription form, statement of work, data processing terms, consent language, or other agreement with a customer. In the event of a conflict between this Privacy Policy and any agreement between WestCoast and a customer, the agreement will control to the extent of the conflict.

If you are a customer of WestCoast, an employee, contractor, driver, operator, fleet manager, or other personnel of a customer, or a visitor to our website, please review this Privacy Policy carefully. By accessing or using our Services, or by otherwise providing personal information to us, you acknowledge that your personal information will be handled as described in this Privacy Policy, subject in each case to applicable law.

1. Scope and Roles

WestCoast provides telematics and fleet management services to commercial, public sector, and other organizational customers in Canada and the United States. Depending on the circumstances, WestCoast may handle personal information in different roles.

Where WestCoast provides Services to a customer and processes personal information on that customer’s behalf in connection with the customer’s fleet operations, WestCoast generally acts as a service provider, processor, contractor, or comparable role under applicable Canadian and U.S. privacy laws, and the customer is responsible for determining the lawful basis or other legal authority for the processing, providing required notices, obtaining required consents or authorizations, and responding to requests from affected individuals, except to the extent applicable law requires otherwise.

Where WestCoast collects personal information for its own business purposes, including account administration, billing, service delivery, security, legal compliance, support, sales, marketing, recruiting, and website operations, WestCoast acts as an organization,

business, controller, or comparable role with direct responsibility for such personal information under applicable law.

Nothing in this Privacy Policy limits a customer’s responsibilities under applicable law or under its agreement with WestCoast, including responsibilities relating to notice, consent or authorization, employee or driver communications, labor or employment-law consultations, workplace monitoring requirements, or other privacy compliance measures.

2. Personal Information We Collect

The personal information that WestCoast collects depends on the nature of the relationship with us, the Services being used, the applicable vehicle systems and OEM integrations, the permissions granted, and the requirements of applicable law.

We may collect the following categories of personal information:

(a) Account and contact information, such as names, business addresses, email addresses, telephone numbers, job titles, usernames, account identifiers, customer numbers, and similar contact or registration information.

(b) Billing and transaction information, such as billing contact information, order details, subscription information, payment-related records, invoice history, tax information, and other commercial records necessary to administer customer accounts.

(c) Vehicle and telematics information, such as VINs, vehicle identifiers, odometer readings, location information, trip history, route history, timestamps, speed, idling, ignition events, maintenance indicators, diagnostic trouble codes, battery or EV (electric vehicle) information, safety events, driver behavior events, and other vehicle or fleet-related information made available through the Services.

(d) Driver and operator information, such as driver identifiers, assigned vehicle information, log-in credentials, work contact details, dispatch information, and information associated with a driver’s or operator’s use of a vehicle or the Services.

(e) Device, usage, and technical information, such as IP address, browser type, device identifiers, operating system, session data, log files, authentication records, API usage records, cookie and similar technology data, and information regarding how users interact with our website, applications, or dashboards.

(f) Communications and support information, such as records of inquiries, support tickets, call recordings or notes where permitted by law, troubleshooting information, training participation, and correspondence with WestCoast.

(g) Marketing and preference information, such as subscription preferences, event participation, lead source information, and records regarding consent to receive commercial electronic messages where required by law.

(h) Employment or candidate information, if an individual applies for a position with WestCoast, such as résumé information, employment history, qualifications, references, and other information provided during recruiting.

In some cases, the personal information processed through the Services may include sensitive information under applicable law, including precise geolocation or information that may reveal employee activity, work patterns, or vehicle usage. WestCoast expects its customers to assess whether such processing is appropriate and lawful in their circumstances and to provide any required notices, policies, consents, or authorizations.

3. Sources of Personal Information

WestCoast may collect personal information directly from the individual, from our customers, from authorized users, from vehicles and telematics devices, from OEMs and other data providers, from business partners, from publicly available sources, from marketing and event partners, and from service providers that support the operation of our business and Services.

Where personal information is provided to WestCoast by a customer or another third party, WestCoast relies on that party to have the necessary authority and legal basis to disclose the personal information to WestCoast.

4. How We Use Personal Information

WestCoast may collect, use, disclose, and otherwise process personal information for the following purposes, as applicable and as permitted by law:

(a) to provide, operate, maintain, support, secure, and improve the Services;

(b) to authenticate users, administer accounts, provision subscriptions, and enable access to dashboards, reports, APIs, tools, and related functionality;

(c) to collect, organize, display, transmit, and make available vehicle, fleet, driver, and related operational data through the Services in accordance with customer instructions and system configuration;

(d) to communicate with customers and users regarding the Services, including service notices, updates, support communications, training, renewal notices, invoices, and administrative matters;

(e) to monitor, troubleshoot, audit, protect, and improve the performance, security, integrity, and reliability of the Services, our systems, and our networks;

(f) to detect, prevent, investigate, and respond to fraud, unauthorized access, misuse, cyber incidents, and other unlawful or harmful activity;

(g) to comply with legal, regulatory, contractual, audit, law enforcement, court order, or insurance requirements;

(h) to establish, exercise, or defend legal claims and to enforce our agreements, policies, and legal rights;

(i) to conduct internal business operations, including finance, billing, collections, recordkeeping, quality assurance, training, analytics, product development, and business planning;

(j) to send marketing, promotional, and business development communications in accordance with applicable law, including Canada’s anti-spam legislation and applicable U.S. electronic marketing laws, and subject to available opt-out rights;

(k) to consider and process employment applications and manage recruitment activities; and

(l) to create aggregated, anonymized, or de-identified information that does not identify an individual, which WestCoast may use for lawful business purposes, including analytics, benchmarking, service improvement, and security.

WestCoast does not use personal information collected on behalf of a customer for unrelated purposes except as permitted by applicable law, required to provide or maintain the Services, required for security or fraud prevention, or otherwise authorized by the customer or by law.

5. Legal Bases and Consent

WestCoast handles personal information in accordance with applicable privacy laws, including, as applicable, the Personal Information Protection and Electronic Documents Act (Canada) (“PIPEDA”), substantially similar provincial private sector privacy legislation, including British Columbia’s Personal Information Protection Act (“BC PIPA”) and Alberta’s Personal Information Protection Act (“AB PIPA“), other applicable Canadian federal or provincial privacy requirements, and applicable U.S. federal and state privacy, consumer protection, and data security laws. In addition, where we provide Services to public sector entities or law enforcement agencies in Canada or the United States, additional statutory

or contractual privacy requirements may apply to the collection, use, disclosure, storage, access, retention, and security of personal information.

Depending on the circumstances and applicable law, WestCoast may rely on consent, contractual necessity, legal authorization, legitimate business purposes or other bases recognized under applicable privacy law, legal obligations, or other lawful authority for the processing of personal information. Where consent, authorization, or notice is required, it may be obtained or provided directly by WestCoast or, in many service delivery contexts, by our customer. Customers are responsible for obtaining and maintaining any consents, notices, or authorizations required for their use of the Services and for their collection and disclosure of personal information to WestCoast.

Subject to legal and contractual restrictions and reasonable notice, an individual may withdraw consent in appropriate circumstances. Withdrawal of consent may affect WestCoast’s ability or a customer’s ability to provide some Services or functionality.

6. Disclosure of Personal Information

WestCoast may disclose personal information as follows, as reasonably necessary and as permitted by law:

(a) to our affiliates and related entities for purposes consistent with this Privacy Policy;

(b) to service providers, subprocessors, contractors, and advisors that assist us in operating our business and providing the Services, including hosting providers, cloud infrastructure providers, telecommunications providers, software vendors, payment processors, support providers, analytics providers, security vendors, auditors, insurers, and professional advisors;

(c) to OEMs, telematics providers, data aggregators, vehicle connectivity partners, and other third-party sources or recipients where necessary to provide the Services requested by a customer;

(d) to the applicable customer and its authorized personnel in connection with the Services;

(e) where required or permitted by law, regulation, subpoena, warrant, court order, lawful access request, or other legal process;

(f) where necessary to establish, exercise, or defend legal claims, protect rights, safety, or property, investigate fraud or security incidents, or enforce our agreements;

(g) in connection with a merger, acquisition, financing, reorganization, sale of assets, or similar corporate transaction, subject to appropriate confidentiality protections; and

(h) with the consent of the individual or as otherwise directed by the customer or authorized by law.

WestCoast does not sell personal information in exchange for monetary consideration in the ordinary course of its business. WestCoast also does not knowingly sell or share personal information, or use personal information for cross-context behavioral advertising or third-party behavioral advertising, in a manner that would be inconsistent with applicable law or our role as a service provider to customers.

7. Law Enforcement and Public Sector Customers

WestCoast may provide Services to police departments, public bodies, municipalities, government agencies, and other public sector or quasi-public sector organizations in Canada and the United States. In those circumstances, WestCoast may be contractually required to implement additional privacy, security, confidentiality, data residency, audit, incident reporting, or records handling controls.

Where WestCoast processes personal information on behalf of such entities, WestCoast does so in accordance with the applicable customer agreement, documented instructions, and applicable law. Requests for access to or correction of personal information held on behalf of such customers should generally be directed to the relevant customer, including the relevant police service or public body, unless applicable law requires otherwise.

Nothing in this Privacy Policy is intended to limit any lawful authority of a public sector customer, including a law enforcement agency, to collect, use, disclose, or retain information in accordance with applicable law.

8. Cross-Border Processing and Data Location

WestCoast is based in British Columbia, and personal information may be accessed, processed, or stored in British Columbia, elsewhere in Canada, in the United States, or in other jurisdictions in which WestCoast, its affiliates, or its service providers operate, subject to applicable law and contractual requirements.

As a result, personal information may be subject to the laws of jurisdictions outside the individual’s province, territory, state, or country of residence and may be accessible to courts, law enforcement, national security authorities, or regulatory authorities in Canada, the United States, or other jurisdictions in accordance with lawful process.

Where required by law or contract, WestCoast will implement reasonable measures intended to provide an appropriate level of protection for personal information transferred across provincial, state, or national borders. Certain customers, including public sector or

law enforcement customers, may require that particular data be stored or accessed only within specified jurisdictions, and WestCoast will address such requirements in the applicable customer agreement where agreed.

9. Retention

WestCoast retains personal information only for as long as reasonably necessary to fulfill the purposes for which it was collected, to provide the Services, to comply with legal, accounting, tax, audit, contractual, or operational requirements, to resolve disputes, and to enforce our agreements.

Retention periods may vary depending on the type of information, the nature of the Services, customer instructions, applicable limitations periods, legal hold requirements, and applicable law. When personal information is no longer required, WestCoast will delete, anonymize, or securely destroy it, or if deletion is not reasonably practicable, securely isolate and protect it until deletion is practicable.

Where WestCoast stores information on behalf of a customer, retention and deletion may be governed by the applicable customer agreement, customer configuration, backup cycles, legal obligations, and record retention requirements.

10. Security Safeguards

WestCoast maintains commercially reasonable administrative, technical, and physical safeguards designed to protect personal information against loss, theft, unauthorized access, use, disclosure, copying, modification, or destruction. These safeguards are designed having regard to the sensitivity of the information, the volume of data processed, the purposes of processing, the nature of our business, and reasonably available technology.

Such safeguards may include, as appropriate, access controls, authentication mechanisms, encryption in transit and at rest where appropriate, logging and monitoring, network and endpoint protections, role-based permissions, confidentiality obligations, secure development and change management practices, vendor diligence, employee training, and incident response procedures.

No method of transmission or storage is completely secure, and WestCoast does not guarantee absolute security. Customers are also responsible for maintaining appropriate security over their accounts, credentials, devices, internal systems, and authorized users.

11. Incident Response and Breach Notification

WestCoast maintains procedures for identifying, assessing, containing, investigating, documenting, and remediating security incidents involving personal information. Where WestCoast becomes aware of unauthorized access to, disclosure of, or loss of personal information under its control, WestCoast will take commercially reasonable steps to contain and assess the incident and to comply with applicable notification, reporting, and recordkeeping requirements.

Where WestCoast acts on behalf of a customer, WestCoast will notify the customer of a confirmed breach or other reportable privacy or security incident affecting customer data as required by applicable law, the applicable agreement, or WestCoast’s incident response procedures, and will provide reasonable cooperation in connection with the customer’s assessment and notification obligations.

12. Accuracy

WestCoast takes reasonable steps appropriate in the circumstances to ensure that personal information used by WestCoast for its own purposes is as accurate, complete, and up to date as necessary for the purposes for which it is to be used.

Because much of the information processed through the Services originates from customers, vehicles, OEMs, telematics devices, and other third-party sources, WestCoast does not guarantee the accuracy, completeness, or currentness of such information. Customers are responsible for reviewing and updating information they provide and for validating information used for employment, disciplinary, safety-critical, legal, or maintenance decisions.

13. Cookies and Similar Technologies

WestCoast may use cookies, pixels, local storage, session replay tools, software development kits, and similar technologies on our websites, portals, and applications to operate and secure the Services, remember preferences, authenticate users, analyze usage, improve performance, and support marketing activities where permitted by law.

Individuals may be able to control certain cookies or similar technologies through browser settings, device settings, cookie banners, or other preference tools. Disabling certain technologies may affect the availability or functionality of parts of the Services.

14. Your Privacy Rights

Subject to applicable law, individuals may have the right to request access to personal information under WestCoast’s control, request correction of inaccurate personal information, request deletion of personal information, withdraw consent in certain circumstances, opt out of certain uses or disclosures, request portability or information

about WestCoast’s privacy practices, or make a complaint regarding WestCoast’s handling of personal information.

Where WestCoast processes personal information on behalf of a customer, WestCoast may refer the request to the relevant customer and may require the customer’s authorization before responding, unless applicable law requires otherwise. This is because the customer is generally in the best position to explain and respond to requests relating to the customer’s own collection and use of information through the Services.

WestCoast may decline a request, or limit the information provided, where permitted or required by applicable law, including where the information is protected by solicitor-client, attorney-client, or other legal privilege, contains confidential commercial information, would reveal personal information about another person, would prejudice security or law enforcement matters, is subject to ongoing investigation or legal process, or where the request is otherwise vexatious, repetitive, or impracticable.

To submit a privacy request, individuals may contact WestCoast using the contact information below. WestCoast may require sufficient information to verify identity before processing a request.

15. Marketing Communications

Where permitted by law, WestCoast may send newsletters, product updates, event invitations, and other promotional communications to customers, prospects, and business contacts. Individuals may unsubscribe from commercial electronic messages at any time by using the unsubscribe mechanism included in the message or by contacting WestCoast.

Even if an individual opts out of promotional communications, WestCoast may still send transactional or service-related communications, including notices relating to accounts, subscriptions, billing, support, security, or changes to the Services or legal terms.

16. Children

The Services are intended for business and organizational use and are not directed to children. WestCoast does not knowingly collect personal information directly from children through the Services for consumer purposes. If WestCoast becomes aware that it has collected personal information from a child contrary to applicable law, WestCoast will take appropriate steps to delete such information or otherwise address the issue in accordance with applicable law.

17. Third-Party Websites and Services

The Services may contain links to third-party websites, applications, integrations, or services that are not operated by WestCoast. This Privacy Policy does not apply to the practices of such third parties, and WestCoast is not responsible for their privacy practices, content, or security. Individuals should review the applicable privacy policies of those third parties before providing personal information to them.

18. Changes to This Privacy Policy

WestCoast may update this Privacy Policy from time to time to reflect changes in our Services, legal requirements, technology, privacy practices, or business operations. Any updated version will be posted with a revised “Last Updated” date and will become effective upon posting or as otherwise communicated, unless a different effective date is required by law.

Where required by applicable law, WestCoast will provide additional notice of material changes or obtain any required consent.

19. Contact Us

If you have questions about this Privacy Policy or WestCoast’s privacy practices, or if you wish to submit an access request, correction request, deletion request, opt-out request, or privacy complaint, please contact:

Privacy Officer WestCoast GPS 2681 Cactus Court, North Vancouver, British Columbia, Canada Email: info@westcoastgps.com Telephone: 778-228-9779

If you are not satisfied with WestCoast’s response to a privacy complaint, you may have the right to contact the privacy regulator or other authority with jurisdiction over your matter, including the Office of the Privacy Commissioner of Canada, the applicable provincial privacy commissioner or oversight body, a U.S. state attorney general, or another applicable U.S. federal or state regulator or agency.