01Our commitment to your privacy
At ULink, trust is not only about carrying a parcel. It is also about how we handle the information you entrust to us.
ULink connects people who want to send parcels with travellers heading to a compatible destination. For this service to work safely, transparently and responsibly, we need to collect and use certain personal information.
We want to do that clearly and reasonably.
This policy explains what information may be collected when you use ULink, why we need it, how it may be used or shared, how long it may be kept, and what choices you can exercise regarding your personal information.
Our goal is simple: collect what is reasonably necessary for ULink to work, protect that information, and avoid using it in a way incompatible with the reasons for which it was obtained.
02Who operates ULink?
ULink is a service operated by UEMPIRE Inc., B-1295 Notting Hill Avenue, Ottawa, Ontario K1V 6T5, Canada.
General email: ulink@uempire.ca — Telephone: +1 514 974 1747.
For questions about the protection of personal information: Personal Information Protection Officer, UEMPIRE Inc., B-1295 Notting Hill Avenue, Ottawa, Ontario K1V 6T5, Canada.
Email: privacy@uempire.ca — Telephone: +1 514 974 1747.
03Who does this policy apply to?
This policy applies to people who use or interact with ULink services, including senders, travellers, recipients when they take part in the journey, Business and Relay users, and other authorised users of the platform.
It also applies to people who contact our support service or use our mobile applications, our web interfaces or other ULink services with which this policy is associated.
Some features may be subject to additional information or notices where a particular processing activity requires it.
04The information we may collect
The information collected depends on how you use ULink.
Account information — We may collect the information needed to create and manage your account, such as your name, your contact details, your language, your country or region and certain account preferences. A profile photo may also be added where that feature is available.
Sign-in and security information — We may process the information needed for authentication, to protect your account, to detect unusual activity and to prevent unauthorised access. Passwords and other authentication secrets must be protected by the security mechanisms the platform uses and must not be exposed in ULink's ordinary interfaces.
Identity verification and KYC — Some features may require identity verification. Depending on the journey concerned and the verification provider used, this procedure may involve information or documents that make it possible to verify your identity. ULink seeks to limit access to this information to the people, systems or providers who genuinely need it. Completing an identity verification does not, on its own, mean that a person is approved for every role or every action on ULink.
Business information and KYB — For Business accounts or features, we may collect information about a business, its representative, its status or other information needed to verify and manage the account. Verifying a business and verifying a person's identity are distinct processes.
Parcel information — When you create or manage a shipment, we may process information such as the parcel description, its category, its dimensions or weight, its declared value, its origin, its destination, the necessary information about the recipient, and the declarations or instructions associated with the shipment. We may also keep the events needed for tracking, the chain of custody and resolving a problem.
Travel information — When a traveller declares a journey, we may process the information needed to represent that journey. A journey may comprise one or more segments and use different means of transport, including plane, train, coach, private or rental car, ferry, or another mode supported by ULink. For air travel, certain public or operational flight information may be used to confirm or track the journey, for example the airline, the flight number, the airports, the schedules and the flight status. ULink does not need a private booking reference, a boarding-pass barcode or private GPS tracking of the traveller simply to track a flight.
Location information — Some features may use location information where it is necessary and where the applicable permissions have been granted. ULink must not turn the tracking of a journey or a parcel into permanent surveillance of the traveller.
Messages and support — When you communicate with other participants in the features provided for that purpose, or with ULink support, we may process the messages and information needed for operation, security and handling the request.
Payments and transactions — Where payment features are used, certain transaction information may be processed by ULink and by the payment providers concerned. ULink seeks to avoid keeping sensitive payment information where it can be handled directly by a specialised provider.
Technical information — We may collect certain technical information needed for the operation and security of the service, for example device type, application version, diagnostic information, security events, IP address or other reasonably necessary technical data.
05Why do we use your information?
We may use personal information in particular to:
- create and manage your account;
- authenticate users;
- provide ULink features;
- connect senders and travellers;
- present and manage offers;
- organise and track shipments;
- represent and verify journeys;
- enable the necessary communication between participants;
- process authorised payment operations;
- respond to support requests;
- carry out the necessary identity or business verifications;
- prevent fraud, abuse and unauthorised access;
- comply with our legal and regulatory obligations;
- enforce the rules applicable to the platform;
- diagnose technical problems;
- improve the reliability, accessibility and security of ULink.
06On what basis do we use your information?
Depending on the nature of the information, where you live and the feature used, processing may in particular be necessary to provide a service you requested, to comply with a legal obligation, to protect ULink and its users, to pursue a legitimate interest recognised by law, or to act with your consent where it is required.
We do not want to present consent as the sole basis for all processing where that is not the case.
07Who may we share certain information with?
We may share certain information only where it is reasonably necessary. This may in particular concern:
- other participants in a transaction, where the information is necessary to them;
- payment providers;
- identity or business verification providers;
- hosting, storage, communication, security or infrastructure providers;
- travel or tracking data providers where those services are used;
- professional advisers where necessary;
- competent authorities where the law requires it or where we must respond to a legally valid request.
08We do not trade in your personal information
ULink does not set out to sell its users' personal information as a product.
If our practices were to change significantly, we would update the information provided to users and apply the corresponding legal requirements.
09International transfers
ULink is designed to facilitate activities that may be international.
Some providers or systems used to deliver the service may process information in other countries.
Where personal information is transferred or processed outside your territory, it may be subject to the laws applicable in the country where it is processed.
We seek to use appropriate measures to protect personal information in the course of that processing.
10How long do we keep your information?
We do not seek to keep all information indefinitely. The retention period depends in particular on:
- the nature of the information;
- the duration of your relationship with ULink;
- operational needs;
- security requirements;
- accounting, tax, regulatory or legal obligations;
- the need to handle a claim, fraud, a dispute or an investigation.
11How do we protect your information?
We use technical and organisational measures intended to protect information against unauthorised access, use, modification, disclosure or destruction.
These measures may include access controls, authentication mechanisms, protection of communications, security logs, separation of duties and controls limiting access to sensitive data.
No computer system can guarantee zero risk. We therefore seek to combine prevention, detection, restricted access and the ability to react.
12What do we do in the event of an incident?
If we discover a security incident involving personal information, we seek to assess its nature, extent and consequences, to contain the problem and to take appropriate measures.
Where the law requires notification to the people concerned or to the competent authorities, we follow the applicable requirements.
13Your rights
Depending on the laws that apply to your situation, you may have certain rights regarding your personal information.
These may include the right to request access to certain information, to request its correction or, in certain circumstances, its deletion.
Other rights may apply depending on your territory and the processing concerned.
To exercise a right or ask a question, you can contact privacy@uempire.ca.
We may need to verify your identity before handling certain requests.
14Withdrawing your consent
Where we use your consent as the basis for processing, you may have the right to withdraw it.
Withdrawing consent does not necessarily make prior uses unlawful and does not remove the obligations ULink must meet independently of consent.
Some features may no longer be available if the information needed for them to work can no longer be used.
15Closing or deleting your account
You can request the closure or, where applicable, the deletion of your account.
Closing an account does not necessarily mean that every piece of information can be deleted immediately.
Some data may need to be kept for an appropriate period for legal, regulatory, accounting, security, fraud-prevention or dispute-resolution reasons.
16Information about recipients
A person sending a parcel may provide certain information about the recipient so that the shipment can be carried out.
The sender must make sure they are authorised to provide the necessary information and that it is accurate.
ULink seeks to limit its use to the operation of the shipment, security, support and applicable obligations.
17Minors
ULink is not intended to allow minors to take on roles or responsibilities that legally require majority.
Where the use of a feature is subject to a minimum age, ULink may take reasonable measures to enforce that requirement.
18Automated decisions and systems
ULink may use automated systems to support the operation, security, anomaly detection or organisation of the service.
We do not want to present an automated decision as a guarantee of a person's reliability or future behaviour.
In particular, a profile photo must not be used to automatically infer a person's reliability, origin, health, religion, criminal behaviour or other sensitive characteristics.
19Communications from ULink
We may send you communications needed for the operation of your account or your transactions, for example security, tracking, booking, support or significant service-change notifications.
Promotional communications, where they exist, must respect the available preferences and the applicable requirements.
20Cookies and similar technologies
ULink's web interfaces may use cookies or similar technologies needed for authentication, security, preferences, operation or reasonable performance measurement.
Where the law requires a particular choice for certain non-essential technologies, we seek to provide the appropriate mechanisms.
21External services
Some ULink features may depend on services provided by third parties.
Those providers may process certain information according to their own obligations and terms.
ULink seeks to limit the data transmitted to what is necessary for the service concerned and to select providers suited to the nature of the processing.
22Changes to this policy
ULink will continue to evolve.
We may update this policy when our features, our practices or the applicable requirements change.
Where the changes are significant, we may use appropriate means to draw users' attention to the new version.
The last-updated date shown at the beginning of the document identifies the published version.
23Languages
This policy may be offered in several languages to make the information more accessible.
Where a translation is provided, we seek to preserve the meaning of the reference version.
Translated versions must not be presented as having undergone independent legal validation if that validation has not actually taken place.
24A question or a concern?
For any general question about ULink: ulink@uempire.ca.
For a question about the protection of personal information: privacy@uempire.ca.
Telephone: +1 514 974 1747.
Address: UEMPIRE Inc., B-1295 Notting Hill Avenue, Ottawa, Ontario K1V 6T5, Canada.
25Our approach
We want privacy protection to be part of ULink's design and not simply a text added after the product has been built.
That means seeking to understand why a piece of information is necessary before collecting it, limiting its use, reducing unnecessary access, explaining important practices understandably, and continuously improving the security of the service.
Trust between a sender and a traveller begins with transparency. Trust between ULink and its users must rest on the same principle.