Introduction and General Concepts
We respect and uphold individual rights to privacy and the protection of personal information. We know how important it is to protect your personal information and want to make every user experience safe and secure. In keeping with that goal, we have developed this Policy to explain our practices for the collection, use, and disclosure of your personal information. We have appointed a Privacy Officer who is responsible for our compliance with this Policy. Information on how to contact the Privacy Officer can be found below.
For the purposes of this Policy, “personal information” means information about an identifiable individual, including, for example, an individual’s name, home address, telephone number and insurance company. Personal information does not include information that would enable an individual to be contacted at a place of business, for example an employee’s name, position or title, business telephone number or business address. We will only collect, use or disclose personal information in accordance with the Policy, or in accordance with laws applicable to the collection, use and disclosure of your personal information by us.
For the purposes of this Policy, “non-personal information” is any type of information, other than personal information, and is excluded from the Policy. For example, non- personal information would include business information, or information that enables an individual to be contacted at a place of business, for example, an employee’s name, position or title, business telephone number or business address. Non-personal information also includes information that is anonymous or not about an identifiable information, such as web browsing information (such as the domain used to access the Website, or the type and version of device, browser or operating system being used to access the Website), or aggregate information that anonymizes the underlying data (like the number of visitors, what pages users visit, average time spent on the Website or on various parts of the Website). We will collect, use or disclose non-personal information in accordance with our ordinary business practices, but always in accordance with any applicable laws. This Policy, however,
only covers our collection, use and disclosure of personal information.
Information about Minors
This Website is not intended for minors and no person under the age of majority may use the Website. We do not knowingly collect personal information about any person under the age of majority, but it varies in different jurisdictions, including any person under the age of 13, and no such person, nor any parent or guardian as it relates to such person, should submit their personal information to us for any reason. Please do not submit personal information about minors to us, whether through the Website or otherwise.
Collection and Use of Personal Information
As indicated above, we collect two types of information through our Website: personal information and non-personal information. The types of information we collect about you will depend on the nature of your interaction with us or the Website.
Information we collect from you
- Contact information such as name, email address, mailing address, phone number and the identity of your insurance company (if known);
- User content generated by you, such as audio and text, as provided by you on the Website, which may contain personal information as provided by you;
- Any information that you voluntarily enter, including personal information, into any postings, comments, review, or forums on the Website.
Information we automatically collect
We also automatically gather information about your computer such as your IP address, browser type, referring/exit pages, operating system as well as which aspects of our performance metric indicators available with our technology or our licensees’ products you prefer using. Some of this may be personal information, but
in typical cases it is non-personal information. Specific examples follow:
- IP, etc. – When using our Website, we may collect the Internet Protocol (IP) address of your computer, the IP address of your Internet Service Provider, the date and time you access our Website, the Internet address of the website from which you linked directly to our Website, the operating system you are using, the sections of our Website you visit, the Website pages read and images viewed, and the content you download from the Website. This information is used for website and system administration purposes, and to improve the Website.
- Cookies – We use “cookies”, a technology that installs a small amount of information on a user’s computer to permit the Website to recognize future visits using that computer. Cookies enhance the convenience and use of the Website. For example, the information provided through cookies is used to recognize you as a previous user of the Website, to offer personalized content and information for your use, to track your activity at the Website, to respond to your needs and to otherwise facilitate your Website experience. You may choose to decline cookies if your browser permits, but doing so may affect your use of the Website and your ability to access certain features of the Website or engage in transactions through the Website.
- Geo-Location Information – When you use the Website through a mobile device, we may track or collect your geo-location information on a real time basis only. We may also use this real-time geo-location information to address support, technical, or business issues that may arise in the course of your use of the Website. If you do not consent to the tracking of your geo-location, you may still be able to use some features of the Website, but it is intended to be used with geo-location information. For example, Subscribers will enter their start location and the Website will track such Subscribers location throughout their trip to the Premises. You may at any time withdraw your consent as permitted through the Website, or, provided you are not Subscriber, you can turn the geo-location tracking off at the device level as permitted by the manufacturer of your device. In our experience, your mobile device informs you when geo-location is tracked by displaying the GPS arrow icon.
Use of Personal Information
We may use your personal information, in combination with your non-personal information, for a variety of business purposes, for example to:
- Fulfill your Request; and
- To enforce our Terms of Service.
The act of willingly providing personal information and non-personal information to us constitutes consent by you for us to collect, use and disclose such information in accordance with the terms and conditions of this Policy.
Subject to legal or contractual requirements, you may at any time withdraw your consent to the collection, use or disclosure of personal information by providing us with written notice of such withdrawal. However, the withdrawal of such consent could limit our capacity to offer certain specific products and services to you, prevent us from providing same or even force us to cease from providing same. Moreover, even in case of withdrawal of consent, we may nevertheless have the right or obligation to retain, use or disclose personal information about you pursuant to applicable law.
Information Obtained from Third Parties
If you provide us personal information about others, or if others give us your personal information, we will only use that information for the specific reason for which it was provided to us and in accordance with this Policy and such policy under which that information was collected.
Disclosure and Sharing of Your Information
We will share your personal information with third parties only pursuant to this Policy. We will not sell your personal information to third parties, however, the use of the Website necessarily requires some sharing or disclosure of your personal information to third parties. Some of these activities may result in personal information collected by us being stored or processed in the United States or elsewhere outside of Canada and, as a result, your personal information may be accessible to law enforcement and regulatory authorities in accordance with the applicable laws of the United States or elsewhere.
Third Party Processors
We may provide your personal information to companies that provide services to help us with the Website such as web hosting providers, payment processors, product shipping provides, fulfilment agencies, or customer service agencies (“Third Party Processors”). These Third Party Processors are authorized to use your personal information only as necessary to provide these services to us, and in a manner consistent with this Policy. We have selected Third Party Processors who will only use your information in compliance with this Policy, but they may have their own specific policies regarding the collection, use and personal information. We will use commercially reasonable efforts to identify such Third Party Processors when we are collecting your personal information, as well as providing links to the relevant privacy policies that may apply. Here are some examples of the Third Party Processors we use as part of the Website:
- Our Service is physically hosted by Zoo Media Group, a reputable hosting platform with industry standard security and practices.
- When you enter a Request for a Subscriber through the Website, we forward certain aspects of the information you provide to the applicable Subscriber to enable it to facilitate the performance of its services. We have entered into arrangements with these parties to ensure that they respect privacy in a manner consistent with this Policy.
- We make your contact information available to Users or Subscribers, as applicable, that you transact with on this site to help complete the transaction, in accordance with your selected preferences.
In addition to the above, we will disclose personal information about Users to third parties only in the following situations:
- The User/Subscriber has expressly authorized us to disclose the information provided for a specific purpose;
- The third parties involved are acting on behalf of us as agents or suppliers
of products or services, and the information will be disclosed to them only in order to assist us in providing products or services, it being understood that these third parties shall respect strict contractual conditions that oblige them to maintain the confidentiality of all information and use it only for purposes related to the supply of products or services by us;
- If a person is acting as a representative of the User/Subscriber or if we reasonably believe that the person is acting pursuant to an appropriate authorization, or is a person who owns a product or service jointly with the User/Subscriber;
- If we are required to provide personal information in response to a court order, subpoena, or are otherwise required to submit documents pursuant to an investigation by authorities or are otherwise required by law;
- We reserve the right to report to law enforcement authorities any activity that we think in good faith to be illegal;
- We may disclose certain personal information when we consider such disclosure reasonably necessary to protect the rights, property and safety of third parties as well as our rights or to ensure Users’/Subscribers’ compliance with its obligation to us;
- Should we sell our business or assets, in whole or in part, or are involved in a merger, as required by such a transaction.
Third Party Links
The Website may contain links to other websites or internet resources, which are provided solely for your convenience and information. When you click on one of those links you are contacting another website or internet resource. We have no responsibility, liability for, or control over, those other websites or internet resources or their collection, use and disclosure of your personal information. We encourage you to read the privacy policies of those other websites to learn how they collect and use your personal information.
Security of Personal Information
The security of your personal information is important to us. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. We employ physical, administrative, contractual and technological safeguards to protect personal information, and use commercially reasonable efforts to ensure that our service providers do the same. We insist that our personnel, and those of our providers, only access and use personal information in order to properly perform those duties, and even then only to the strict
extent necessary to perform them.
Requests for Access to and Correction of Personal Information
Applicable laws allow, to varying degrees, individuals the right to access and/or request the correction of errors or omissions in his or her personal information that is in our custody or under our control. Our Privacy Officer will assist you with such an access request. This includes:
- Identification of personal information under our custody or control;
- Information about how personal information under our control may be or has been used by us; and
- The names of any individuals and organizations to which the individual’s personal information has been disclosed.
Any such request must contain sufficient details for us to be able to process same. We will respond to requests within the time allowed by applicable laws and will make every effort to respond as accurately and completely as possible. We must, however, first verify the identity of the person making such a request. Any corrections made to personal information will be promptly sent to any organization it was disclosed to. In certain exceptional circumstances, we may not be able to provide access to certain personal information it holds about an individual. If access cannot be provided, we will notify the individual making the request within 30 days, in writing, of the reasons for the refusal.
We may refuse in writing access to or modification of personal information of a User for serious reasons, such as the exorbitant cost of supplying the information, the fact
that the personal information contains information about other persons, the existence of legal, security or proprietary commercial reasons and the fact that the
information is protected by professional secrecy, attorney-client privilege, or involved in a legal proceeding.
We may charge fees for the transcription, copying or transmission of Personal Information of a User and we will so advise the User in advance.
Removal of Your Information
We keep your information only as long as we need it for legitimate business purposes and to meet any legal requirements. Personal information used to make a decision that directly affects an individual will be kept for at least one year after such a decision. We have retention standards that meet theses parameters. We destroy your information when it is no longer needed o required to be kept, or we remove your
personally identifiable information to render it anonymous.
You can direct any questions or concerns regarding our compliance with this Policy to our Privacy Officer by writing or emailing at:
P.O. Box 21054
Wonderland Road South, RO PO London ON N6K 0C7
If you are not satisfied with our Privacy Officer’s response to your questions or concerns, you may be able to make a complaint under Applicable Laws. Our Privacy Officer can provide you with the contact information to make such a complaint.