Policies

Privacy Statement

For the purposes of this Privacy Statement, ONxpress includes its partners and affiliated corporations.

This Privacy Statement was last updated: March 9, 2025.

ONxpress may collect personal information from different sources depending on the services that we are providing or whether we are collecting this personal information for our internal business operations. For example, we may collect personal information directly from you when you retain us or your employer when your employer retains us. We may also collect personal information from you when you apply for employment or an internship with us. We may also collect personal information through third parties who perform background checks and credit checks for us. In addition, we may collect personal information through third party analytics and advertising firms who assist us in our marketing. These businesses may provide us with data about your online activities on other sites where we show our advertising and marketing material.

We collect the following types of personal information:

• Contact information, such as your name, title, role, employer, telephone, email address, and mailing address.
• Visitor information when you attend at our offices or events, such as your name, company, and persons you visited at our offices and events.
• Public profile information, such as information that you have made public on LinkedIn or your company’s website.
• Communications, such as the content of your emails, voicemails, and other communications with us
• Communication preferences and interests, such as when you subscribe to receive our newsletters, updates, or other materials.
• Feedback, such as when you fill out client surveys or feedback forms at our events.
• Recruitment information, such as information contained in CVs and cover letters, references, and other information you may provide if you apply for employment or an internship, or that we collect as part of our recruitment activities.
• Background check information, such as credit checks, criminal records checks, economic, and other sanctions checks, credential checks and other background information.
• Portal/Vendor registration information, such as email address, password, and activities using our client portal, if applicable.
• Device and browser information when you use our website www.onxpress.com, such as your IP address, browser type and version, time zone setting, operating system, device type, hardware model, MAC address, and network information.
• Browsing information when you visit our website, URL clickstream data about your visit to, through and from our website, page response times, downloads, and length of visits and interaction information.
• Marketing interaction information, such as whether you opened one of our electronic newsletters or clicked on an advertisement or otherwise interacted with our marketing materials.

The purposes of our collection, use, sharing and disclosure:

We may collect, use, share or disclose personal information for the following purposes:

• Vendor management, such as managing the services that third parties deliver to us or to client(s) on our behalf.
• Legal and regulatory compliance, such as conducting screening for conflicts, complying with anti-money laundering laws, conducting sanctions checks, and to maintain books and records that are required by law or that assist us in meeting our legal and regulatory obligations.
• Relationship management, such as establishing, maintaining, and administering our relationship with you or your employer, and which may include client account opening, accounting, invoicing, risk analysis, conflict checking, and customizing the services we offer to our client(s).
• Recruitment, such as processing your application for employment or an internship or when we proactively recruit new employees or co-op placements.
• Communications, such as responding to your inquiries, sending you newsletters, updates, or other material, and managing your preferences.
• Events management, such as reserving your place at our events, noting dietary restrictions or choices, and other event related purposes.
• Feedback, such as client surveys, event feedback, and addressing concerns that you might have attended and shared your information with ONxpress.
• Security, such as monitoring who has had access to our premises, and protecting our website from misuse.
• Website management, such as monitoring what visitors, visit our website, and whether there are problems with features and functionality.
• Improvement of our business, understanding what our visitors, prospective employees and vendors find interesting, improving our website, improving how we use vendors to provide services to us or to our clients.

Sharing Personal Information: We may disclose or share personal information in order to fulfill legal requirements or to operate, market, and improve our business.

The following are examples of entities that may receive personal information with from us. These entities will only use your personal information in accordance with our instructions or as otherwise required by law:

• ONxpress members, stakeholders and partners, when necessary to vet services or products across multiple business units, to make referrals, to assess potential conflicts.
• Service providers, who provide outsourced business services to us, who assist us in marketing and advertising or events, or who assist us in providing or managing our information technology and communications systems.
• Screening service providers, who perform credit checks, sanctions screening, crime or anti-money laundering checks, and other background checks.
• Clients, as part of work product, such as when we are retained to conduct an audit or investigation or prepare a report or advice, and your personal information is relevant to that work product.
• Analytics providers and advertising networks, who support our analysis of the performance of our website, microsites and mobile apps and your interests, or who assist us in placing advertising on other sites.
• The following are examples of entities that we may disclose personal information to. In situations involving such disclosure, ONxpress has no control over how these entities may use your personal information: Emergency responders, emergency contacts, or public health authorities, when necessary to respond to an emergency, or address an urgent occupational health and safety issue or outbreak of communicable diseases.
• Law enforcement bodies and regulators, when required under applicable laws, such as anti-money laundering reports, or where we are reporting a contravention of laws.
• Other third parties, in the course of a commercial transaction involving the acquisition of or transfer of any part of our business.

Consent and other legal bases

There may be several reasons why we might collect, use, share or otherwise handle your personal information. These include:

• Your explicit or implicit consent, such as when you provide the personal information as part of a request for services or a product, when you provide the personal information for a specific purpose or we ask you to consent to our use of your personal information for a purpose or for the purposes set out in this Privacy Statement.
• With the consent of someone with authority to provide the information to us, such as your employer or a third party to whom you provided the information and who has the legal right to share it with us.
• Where necessary to fulfill our legal obligations, such as where we need to conduct client screening, anti-money laundering checks, or for other legal and compliance purposes where the law permits us to handle personal information with your consent.
• For the purposes of responding to legal claims against us.
• To conduct investigations where the law permits us to handle personal information without your consent.

We may use your business contact information to contact you in your business, role, function, or occupation without your consent. If we send you commercial electronic messages, we will comply with Canada’s Anti-Spam Legislation, subject to any exceptions permitting us to send unsolicited commercial electronic messages. You may unsubscribe from our communications at any time.

Security

We use physical, technical, and organizational security measures that are consistent with standards in our industry. These security measures are designed to protect the confidentiality and integrity of personal information in our custody. We use contractual or other means to require our service providers to protect the confidentiality and integrity of personal information we entrust to them. Unfortunately, no system of security measures can guarantee the security and privacy of personal information. If you are sharing highly sensitive information electronically with ONxpress, please speak with us about methods of secure file transfers.

Location and retention

Personal information is stored primarily in Canada. However, we may also use service providers or the assistance of partners, except where we are restricted by legal or contractual requirements. The laws of other jurisdictions may not be as protective as those in Canada and personal information held outside of Canada may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of these other countries in accordance with their laws.

We retain information for the purposes for as long as it is necessary to fulfill the purposes for which we collected it. We also retain personal information to meet obligations under applicable laws and regulatory requirements and to maintain records for possible litigation or investigations, where required.

Children and minors

We do not knowingly collect personal information from children or other persons who are under 14 years of age except as part of our engagements such as career exploration, bring your child to work days or where a child is brought into our office as a visitor and may require a visitor pass. Our website and marketing materials are only for use by individuals who have reached the age of majority in their province or country of residence.

Analytics

Our websites may use analytics services, including Google Analytics, a web analytics service provided by Google, Inc. These analytics providers use cookies to help the website analyze how users use the site. In some cases, the information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by analytics providers on servers outside of Canada. This information is used for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage.

Your choices

If you would prefer not to accept cookies, most browsers will allow you to:

(i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it;

(ii) disable existing cookies or delete cookies when you close your browser; or

(iii) set your browser to automatically reject any cookies. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.

You can opt-out of network advertising programs that track your activities across multiple websites to deliver personalized advertising content to you. Please visit Digital Advertising Alliance of Canada Opt-Out Page, NAI Opt-Out Page and the Ad Choices Opt-Out Page. These websites provide tools that identify member companies that have placed cookies on your browser and provides mechanisms to opt-out of those cookies. You will still receive other types of advertising from participating companies; however, it will not be based on your interests. Deleting browser cookies can remove your opt-out preferences, so you should use these tools periodically to ensure that your preferences are up-to-date.

Your rights:

Canadian privacy laws provide you with certain rights, including those listed below. Please see “How to contact us” for the contact information in order to exercise these rights.

• Access– you have the right to ask us if we have collected personal information about you and to obtain access to that information. Where you wish to exercise this right, we will ask you for information to confirm your identity and may ask you to assist us in describing your relationship with us so that we can locate the relevant personal information. Please note that we may withhold disclosure of personal information in certain cases under applicable laws.
• Correction – you have the right to ask us to correct any incorrect, incomplete or inaccurate personal information we hold about you.
• Withdrawal of consent – in some cases, you have the right to ask us to cease collecting, using, or sharing your personal information.
• Complaints – you have the right to make a complaint to about our compliance with this Privacy Statement or applicable privacy laws. Changes

We may change this Privacy Statement from time to time. Please refer to the date at the top of this Privacy Statement for the last date updated.

How to contact us:

To exercise your rights or to make a complaint, please contact:

Attn: ONxpress Transportation Partners

130 Adelaide Street West, 5th Floor

Toronto, ON M5H 0A1

Disclaimer and Terms of Use

​Visitors to our website and users in general should note that:

The use of our website is solely at their own risk on an "as is", "as available" basis. Information on our website is provided for general purposes only.

ONxpress makes no warranty or representation as to the accuracy, quality or completeness of any information on our website. ONxpress disclaims all warranties and conditions including merchantability and fitness for a particular purpose, either express or implied, and disclaims any liability for loss or damages which result directly or indirectly from the use in any form of any of the information on our website including any personal information provided by visitors and users in general. Where such warranties or conditions are legally incapable of exclusion, then ONxpress’s liability shall be limited to the sum of $100.00 in the aggregate regardless of the number of occurrences. Users assume all risks concerning the suitability to their needs and the accuracy of information on our website and any publications therein.

The use of this website or any e-mail communication to any one at ONxpress does not give rise to a client relationship notwithstanding receipt of such communication. A client relationship shall only arise upon our mutual agreement in writing.

Internet communications may not be confidential and ONxpress does not guarantee the confidentiality of any e-mail or internet transmissions. Users are cautioned not to send any information where confidentiality or privacy may be an issue via e-mail or the internet. ONxpress assumes no liability whatsoever for any confidential information sent to us over the internet.

ONxpress expressly disclaims any liability regarding links to other websites or any information, products, or services that they contain.

Any legal questions or disputes arising from the use of our website shall be governed by the laws of the Province of Ontario and the laws of Canada applicable therein. The courts of the Province of Ontario shall have primary jurisdiction over any such legal questions or disputes.

For the purposes of this Disclaimer, ONxpress shall include its partners, principals, officers, directors, employees, agents, authorized representatives as well as its affiliated corporations and their respective officers, directors, shareholders, employees, agents, and authorized representatives.

ONxpress reserves the right to make changes at any time to the website which may include information including these terms, services, and technical specifications, without notice. Users are responsible for checking such updates.

Cookies

Below we provide information on how we may use website cookies on our website.

A cookie is a small data file of information offered to your computer or device by web servers to keep track of your browser as you navigate our websites. Using this information, we learn how you interact with our websites, how we can improve the design and content of our websites and improve your experiences. We do not use cookies to access personal files on your computer or device.

Our website, advertisements, and email communications may use pixel files. Pixel files keep track of your browser or your interaction with our advertisements and marketing material. We may also use pixel files to determine when you have opened a promotional communication from us.

Our ad management providers may use cookies and pixel files to populate an advertisement for us when you visit certain other websites.

Copyright

All content on this website, including but not limited to text, images, graphics, logos, and any other materials, is the property of ONxpress or its content providers and is protected by copyright laws in Canada and internationally. Unauthorized reproduction, distribution, modification, or transmission of any content without prior written consent from ONxpress is strictly prohibited. Users are granted a limited, non-exclusive, non-transferable license to access and use the website for personal, non-commercial purposes only. Any unauthorized use may result in legal action.

1. PURPOSE

ONxpress Transportation Partners Inc. (the “Company” or “ONxpress”) is committed to treating all people in a way that allows them to maintain their dignity and independence. We believe in integration and equal opportunity. We are committed to meeting the needs of people with disabilities in a timely manner and will do so by preventing and removing barriers to accessibility and meeting accessibility requirements under the Accessibility for Ontarians with Disabilities Act, 2005 (AODA). We strive to operate our business in a manner that respects the dignity and independence of persons with disabilities.

The purpose of this accessible customer service policy (the “Policy”) is to set out the principles that guide ONxpress on its path to accessibility through compliance with the Accessibility for Ontarians with Disabilities Act, 2005 (the “AODA”) and, in particular, its Integrated Accessibility Standards (Ontario Regulation 191/11). The AODA and its standards are not a replacement or substitution for the requirements of the Human Rights Code (Ontario).

2. SCOPE

This Policy applies to all Employees of ONxpress (including for certainty Seconded employees while seconded to ONxpress) as well as persons who provide goods, services or facilities on behalf of ONxpress. For clarity, this Policy does not apply to the Company’s affiliates or shareholders. Additionally, this Policy applies to ONxpress’ provision of goods and services in Ontario to its customers, members of the public and other applicable third parties. This Policy will be implemented in accordance with the timeframes established by the Integrated Accessibility Standards.

3. COMMITMENT STATEMENT

ONxpress is committed to identifying and meeting the accessibility needs of persons with disabilities in an effective, appropriate, and timely manner through compliance with the Integrated Accessibility Standards. ONxpress’ goal is to foster an inclusive organizational culture that is guided by the principles of the AODA and the Integrated Accessibility Standards, which include: (i) dignity; (ii) independence; (iii) integration (except when alternate measures are necessary to meet the needs of people with disabilities); and (iv) equal opportunity.

ONxpress strives at all times to provide its goods and services to the public and applicable third parties in a way that respects the dignity and independence of persons with disabilities. ONxpress is also committed to giving persons with disabilities the same opportunity to access and benefit from its goods and services as other members of the public.

4. DEFINITIONS

Accessible formats are formats that are an alternative to standard print and are accessible to people with disabilities. They may include, but are not limited to large print, recorded audio and electronic formats, Braille, and other formats usable by persons with disabilities.

Accommodation means the special arrangement(s) made, or assistance provided, so that persons with disabilities can participate in the experience available to persons without disabilities, subject to reasonable limits prescribed by the Ontario Human Rights Code. Accommodation will vary depending on an individual’s unique needs.

Communications supports are supports that individuals with disabilities may need to access information. They may include, but are not limited to, captioning, alternative and augmenting communication supports, plain language, sign language, and any other supports that facilitate effective communications.

Assistive Devices are auxiliary aids such as communications aids, cognition aids, personal mobility aids, and medical aids (e.g. canes, crutches, wheelchairs or hearing aids).

Disability according to the Ontario Human Rights Code, as referenced by the AODA means:

• any degree of physical disability, infirmity, malformation or disfigurement that is caused by bodily injury, birth defect or illness and, without limiting the generality of the foregoing, includes diabetes mellitus, epilepsy, a brain injury, any degree of paralysis, amputation, lack of physical co-ordination, blindness or visual impediment, deafness or hearing impediment, muteness or speech impediment, or physical reliance on a guide dog or other animal or on a wheelchair or other remedial appliance or device;
• a condition of mental impairment or a developmental disability;
• a learning disability or a dysfunction in one or more of the processes involved in understanding or using symbols or spoken language;
• a mental disorder; or
• an injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act, 1997.

Employees – mean all salaried, full-time employees of the Company and includes Seconded Employees.

Persons with Disabilities – are individuals who have a disability as defined under the Ontario Human Rights Code.

Seconded Employee – means an employee of an affiliate of the Company who has temporarily been seconded to the Company to meet an operational need, training/learning aim, career development purpose and/or knowledge transfer purpose.

Service Animals – are animals used by a person with a disability for reasons relating to their disability.

Support Persons – are means, in relation to a person with a disability, another person who accompanies the person with a disability in order to help with communication, mobility, personal care or medical needs or with access to goods, services or facilities.

5. PROCEDURES

5.1 Accessibility Policy

ONxpress has prepared and will maintain this Policy to describe the principles that guide our path to accessibility as an organization and identify what ONxpress will do to meet the requirements of the Integrated Accessibility Standards.

5.2 Providing Goods and Services to Persons with Disabilities

ONxpress is committed to excellence in serving all clients, including persons with disabilities. It will provide its services and communicate with customers, members of the public and applicable third parties to whom it provides goods and services at its Ontario premises, if any, in a manner that takes into account a person’s disability. In particular:

Communication: The Company recognizes that persons with disabilities may require the use of assistive devices. As such, the Company will take all reasonable measures to ensure that its premises are conducive to the use of such devices. ONxpress employees will make all necessary accommodations, up to the point of undue hardship on the Company, to enable clients to use assistive devices as required to access its services. Further, we will be trained and familiar with various assistive devices that may be used by clients with disabilities while accessing its services.

Telephone services: The Company is committed to providing fully accessible telephone service to our clients. We will train employees to communicate with clients over the telephone in clear and plain language and to speak clearly and slowly. The Company will offer to communicate with clients by e-mail, or letter if telephone communication is not suitable to their communication needs or is not available.

Assistive devices: The Company is committed to serving persons with disabilities who use assistive devices to obtain, use or benefit from our goods and services. ONxpress will ensure that our employees are trained and familiar with various assistive devices that may be used by clients with disabilities while accessing our goods or services.

Billing: The Company is committed to providing accessible invoices to our client if needed.

5.3 Use of Service Animals and Support Persons

ONxpress is committed to welcoming persons with disabilities who are accompanied by a support person. Any person with a disability who is accompanied by a support person will be allowed to enter ONxpress’ premises with his or her support person. At no time will a person with a disability who is accompanied by a support person be prevented from having access to his or her support person while on our premises. Permission will be obtained from the person with the disability prior to a discussion of a confidential nature taking place with the support person present. To the extent permitted by law, the Company will also be sensitive to any accommodations that may be necessary as a result of the use of a service animal.

When ONxpress’ employees cannot easily identify that an animal is a service animal, employees may ask a person to provide documentation (letter or form) from a regulated health professional that confirms the person needs the service animal for reasons relating to their disability. A service animal can be easily identified through visual indicators, such as when it wears a harness or a vest, or when it helps the person perform certain tasks. In cases where a service animal is excluded by law from the premises, the Company will ensure that other measures are available to enable a person with a disability to obtain, use or benefit from the provider’s goods, services or facilities.

5.4 Notice of Temporary Disruption

ONxpress will provide appropriate parties with notice in the event of a planned or unexpected disruption in the facilities or services provided by ONxpress which are usually used by persons with disabilities, if any. This notice will include information about the reason for the disruption, the anticipated duration, and a description of alternative facilities or services, if available. The notice will be placed at all public entrances and reception counters on our premises.

5.5 Training for Employees

ONxpress will ensure that the following persons receive training about its goods, services, or facilities, as the case may be, to persons with disabilities:

(a) all of its employees and volunteers;

(b) all persons who participate in developing ONxpress’ policies; and

(c) all other persons who provide goods, services or facilities on behalf of ONxpress.

Training will include a review of the purposes of the AODA and the Integrated Accessibility Standards as well as instruction about the following:

• How to interact and communicate with persons with various types of disabilities;
• How to interact with persons with disabilities who use an assistive device or require the assistance of a service animal or a support person;
• How to use equipment or devices available on ONxpress’ premises or otherwise provided by ONxpress that may help with the provision of goods, services or facilities to a person with a disability; and
• What to do if a person with a disability is having difficulty in accessing ONxpress’ goods, services or facilities.

Employees will also be trained on an ongoing basis when changes are made to these policies, practices, and procedures. New employees will also be provided with such training upon hire.

Where third parties are engaged to perform services in Ontario on behalf of ONxpress, ONxpress may require that such third parties provide an acknowledgement that their principals, employees, agents and volunteers receive any applicable training required by the AODA.

5.6 Employment

ONxpress’ policies and practices are intended to build an inclusive and accessible work environment that is free from discrimination and harassment.

• Recruitment: In our recruitment processes, ONxpress will advise our employees and the public about the availability of accommodation for applicants with disabilities.
• Recruitment, Assessment or Selection Process: ONxpress will notify job applicants, when they are individually selected to participate further in an assessment or selection process, that accommodations are available upon request in relation to the materials or processes to be used. If a selected job applicant requests accommodation relating to their participation in the hiring process, ONxpress will consult with the individual and provide or arrange for the provision of suitable accommodation that takes into account the applicant’s disability-related needs.
• Notice to Successful Applicants: When making offers of employment, ONxpress will notify successful applicants of our policies for accommodating employees with disabilities.
• Informing Employees of Supports: We will notify our employees of ONxpress’ policies (and any updates to those policies) for supporting employees with disabilities, including our policies regarding the provision of job accommodations that take into account an employee’s accessibility needs due to disability. This information will be provided to new hires as soon as practicable after they commence employment.
• Accessible Formats and Communication Supports for Employees: If an employee with a disability asks for information in an accessible format or to receive communication supports, ONxpress will consult with the employee to provide, or arrange for the provision of, accessible formats and communication supports for information that the employee needs to perform his/her job, as well as information that is generally available to other employees. In determining the suitability of an accessible format or communication support, ONxpress will consult with the employee making the request.
• Workplace Emergency Response Information: ONxpress will provide individualized workplace emergency response information to employees with disabilities where the disability is such that individualized information is necessary and ONxpress is aware of the need for accommodation. ONxpress will provide workplace emergency response information as soon as practicable after learning of the need for accommodation due to an employee’s disability. Where an employee who receives individualized workplace emergency response information requires assistance, ONxpress will designate a person to provide assistance and, with the employee’s consent, ONxpress will provide the workplace emergency response information to such person. ONxpress will review individualized workplace emergency response information, at minimum, whenever:

- the employee moves to a different location within ONxpress,

- the employee’s overall accommodation needs or plans are reviewed, or

- ONxpress reviews its general emergency response policies.

• Performance Management, Career Development and Advancement & Redeployment: ONxpress will take into account the accessibility needs of employees with disabilities, as well as individual accommodation plans, when conducting performance management, providing career development and advancement to employees, or when redeploying employees.
• Documented Individual Accommodation Plans: ONxpress will develop and maintain a written process for the development of documented individual accommodation plans for employees with disabilities. If requested, information regarding accessible formats and communications supports provided will also be included in individual accommodation plans. Additionally, the plans will include individualized workplace emergency response information (where required). Plans will also identify any other accommodation that is to be provided.
• Return to Work Process: ONxpress will develop and maintain a documented return to work process for its employees who have been absent from work due to a disability and who require disability-related accommodations in order to return to work. The return-to-work process will, as part of the process, outline the steps that ONxpress will take to facilitate the return to work and will include documented individual accommodation plans. This return-to-work process will not replace or override any other return to work process created by or under any other statute (for example, the Workplace Safety and Insurance Act, 1997).

5.7 Questions about this Policy

This Policy exists to achieve service excellence for all customers, including people with disabilities. If anyone has a question about the Policy, or if the purpose of the Policy is not understood, questions may be posed to ONxpress Human Resources

5.8 Feedback Process

An ultimate goal of ONxpress is to meet or surpass customer expectations while serving all clients, including people with disabilities. Comments on how our goods and services are provided to persons with disabilities in Ontario are welcome and appreciated. ONxpress will continue to ensure that its processes for receiving and responding to feedback are accessible to persons with disabilities by providing, or arranging for the provision of, accessible formats and communications supports, upon request. Members of the Public, our Client and Third Parties may provide feedback via various methods:

Mail: ONxpress Project Co. Human Resources Department

130 Adelaide St West, Toronto ON M5J 2T3

The feedback and complaints processes has been developed in inclusive modes, catering to the needs of persons with accessibility needs due to disabilities.

When complaints and/or feedback are received, they will follow the usual path of being responded to, as quickly as practicably possible.

ONxpress will make best efforts to acknowledge all complaints within 7 business days.

5.9 Notice of Availability of Documents

This document is posted on ONxpress’ website in an accessible format. ONxpress will post a notice on the Company website for any changes to the procedures, practices, or policies.

ONxpress will provide this document in an accessible format or with communication support, on request. We will consult with the person making the request to determine the suitability of the format or communication support. We will provide the accessible format in a timely manner and at no additional cost.

6. MONITORING AND REVIEW

This Policy will be reviewed as necessary and at least once every year. The Chief Human Resource Officer, or successor thereof, is responsible to monitor and review this Policy. No changes are made to this Policy before first considering the impact on persons with disabilities. 7.

7. REFERENCES

Ontario Human Rights Code Employment Standards Act, 2000 Accessibility for Ontarians with Disabilities Act, 2005 O. Reg. 191/11 – Integrated Accessibility Standards under Accessibility for Ontarians with Disabilities Act, 2005