Privacy Policy.
Effective: November 2nd, 2021
The Privacy Policy outlines the manner in which OpenMobile Inc., operating as OpenMobile (hereafter "openmobile", "we", "our" or "us"), collects, uses, discloses and otherwise manages personal information, including in connection with our website www.openmobile.ca (the "Website") and our mobile customer application (the "App") (collectively, the "Service"). Please review the following carefully so that you understand our privacy practices
In addition to this policy, we may also provide you with additional information through prompts, on-line notices and our website’s Terms of Use. There may also be product specific or service specific privacy policies which we will provide you at the time of your specific interaction or purchase.
Some of our marketplace partners may have their own privacy policies which you should read, understand and consent to before interacting or purchasing from them.
1. What Is “Personal Information”?
Personal information is information that can identify an individual or is about an identifiable individual. Personal information can include:
- your name, address, email address and telephone number;
- IP address;
- device ID;
- opinions, evaluations, comments, reviews of products and services; or
- other information about the products and services you purchase or use.
- Voicemail and corresponding transcription
2. What Information Do We Collect And For What Purpose?
We collect personal information for the purposes of providing you relevant and tailored products and services and to establish and maintain responsible commercial relations with you. For example, we may collect personal information for the following purposes:
| PERSONAL INFORMATION WE MAY COLLECT | PURPOSE FOR COLLECTING PERSONAL INFORMATION |
| First name and surname | To create your account, verify your identity and personalize your experience. |
| Social media username and photo from Facebook or Google (requires consent to link to your social network profile) | With your prior consent, we may collect this information to create your account, verify your identity and personalize your experience. |
| E-mail address | To create and help secure your account, verify your identity, enable account recovery and to communicate with you |
| Address and postal code | For shipping purposes, analytics and to personalize your experience. |
| The last four digits of your credit card | To identify specific payment method in checkout, render statements, track order history, and for fraud prevention. |
| Geo-location (requires in-app consent) | To power Connectivity Intelligence features, analytics, and to personalize your experience. When you use the App through your mobile device, we may track your precise or approximate location through GPS, IP address or Wi-Fi. |
| Interactions with the Website and App such as likes, comments, reviews | To understand your preferences and tailor relevant content to your specific likes and interests. To help other users of the service (members) to make better purchasing decisions and to better inform them about various aspects of the service. |
| Website or App usage such as access dates and times, features used, web pages viewed, crashes and other system activity, and third-party sites you were interacting with before using our services. | To better understand how the Website or App are used, fix bugs, and improve the experience. |
| Technical data such as IP address, Device ID, MAC address, device properties, internet browser, session information, network type, and signal strength. (in-app consent required for on-device information) | With your prior consent, we may collect this information to power certain features of the website or App. We may also use the information to help prevent fraud, perform analytics, fix bugs and improve the experience. |
| Career information | To register and process your application, to determine your qualifications for the position for which you have applied, and to contact you. |
| Interactions with our chatbot | A transcription of your communication with our chatbot is created and retained during every interaction. The purpose of this transcript is to train the chatbot to refine the accuracy and helpfulness of this system. |
We may also use your information to communicate with you for purposes which may include:
| TYPE OF COMMUNICATION | |
| Account | To authenticate and ensure your information is correct and up to date, for example, to verify your e-mail address. Also, to communicate with you about your account activity including any changes to your account. |
| Direct marketing and promotional materials | If we have your prior consent, we will communicate with you about:
|
| Support resolution |
|
| Service notifications |
To provide timely updates about services that you are using, for example:
|
| Other | Complying with regulatory requirements. |
3. How Do We Collect Your Personal Information?
We collect your information from different sources, which may include:
| FROM WHOM? | HOW IS YOUR PERSONAL INFORMATION COLLECTED? |
| You | From you directly entering your information on our website, creating an account, interacting with AI chat bot, using our services, consenting to our use of Cookies and other similar technologies. |
| Third party sources |
|
4. To Whom Do We Disclose Your Personal Information?
We are serious about safeguarding your personal information, including maintaining controls for employee and third-party access to your personal information.
We may share your personal information with our service providers. In providing our services, we may use third-party service providers to, for example, help perform administrative functions, service our products, or fulfill on-line orders. Some of these third-party service providers may be located outside of Canada, including the United States or Lithuania. As a result, your personal information may be accessible to law enforcement, courts and regulatory authorities in accordance with the laws of these foreign jurisdictions.
In the event of a sell, assignment, or other transfer of all or a portion of our business or assets, information we might have about you might be transferred or disclosed to a purchaser or prospective purchaser. Should such a transfer occur, we will use reasonable efforts to try to ensure that the transferee uses your information in a manner that is consistent with this Policy unless otherwise permitted or required by applicable law.
In addition, we may be compelled to share your information with a court of law or other person(s) or entity/entities with jurisdiction to compel production of such information.
We do not sell or rent your personal information to any party. Should we wish to participate in programs that monetizes the data you generate through the use of our services, we will obtain your consent before participating and we will provide you with specific information about the program, including what data would be involved.
5. Where Do We Store Your Personal Information?
We store all personal information that we collect from you or about you on Google Cloud Platform servers located in Toronto, Ontario, Canada. As noted, from time to time your personal information may be transferred to third-party hosts outside of Canada to facilitate or provide certain services on our behalf, such as to process payments, provide Member support, provide geo-location information, to host our job application forms, to perform Website-related services (e.g., without limitation, maintenance services, database management, web analytics and improvement of the Website's features) or to assist us in analyzing how our services are used.
These third parties have access to your personal information only to perform these tasks on our behalf and are contractually bound not to disclose or use it for any other purpose. For additional information about the way in which our service providers treat your personal information, contact us at info@openmobile.ca .
By using our Website and/or App, you consent to the transfer of your personal information outside of your jurisdiction for the purpose of storing your personal information or processing it.
6. How Do We Use Data Analytics?
Our website uses Google reCaptcha and Google Analytics services which transmit website usage data to Google servers. We use reports provided by Google Analytics to help us understand non-personal facts and figures about users of the website such as:
- website traffic;
- number of visitors;
- location of visitors;
- information about the browser version and device type;
- referral sources to the website;
- demographics of visitors;
- and website usage (including the goal conversion, flows, behaviour).
For more information please visit https://policies.google.com/technologies/partner-sites
7. What Are Cookies And Related Technologies?
Cookies are industry standard and most websites use them. A cookie is a small text file which our website may place on your computer as a tool to remember your preferences and display more relevant information next time you visit. You may refuse to use cookies by selecting appropriate settings on your browser, however, please note that if you disable cookies, you may not be able to use the full functions of our service.
For more information, please see our Cookies Policy.
8. How Do We Respect Children’s Privacy Online?
the Website is not directed, marketed, or meant to be used by children under the age of thirteen (13). If you think you child might have created an account with us without your consent, you may request the deletion of the account and the data that we have about your child by writing to us at support@openmobile.ca.
9. How Long Do We Retain Your Personal Information?
We will generally retain your personal information for as long as is necessary to meet our contractual obligations to you, to satisfy the purposes stated above or as otherwise required by law.
When determining the relevant retention period, we consider:
- our contractual obligations and rights in relation to the information involved;
- legal obligation(s) under applicable law to retain data for a certain period of time;
- statute of limitations under applicable law(s);
- our legitimate interests where we have carried out balancing tests (see section on 'What Information do we collect and for what purpose' above);
- guidelines issued by relevant data protection authorities; and
- other legal purposes
In addition to the above, your personal information may be anonymized and used in aggregate. We may also retain your profile to welcome you back in case you decide to reinstate your member profile or service account at a later date. Once it is determined that your personal information is no longer necessary as indicated above, we will securely erase your personal information.
You may also request the deletion of your profile by sending an e-mail to support@openmobile.ca. It may take up to twenty (20) business days to respond to your request. If you wish to request that we cancel or delete your account, you may do so by contacting us at support@openmobile.ca.
10. How Do We Safeguard Your Personal Information?
Our safeguards: We take appropriate technical, physical and organizational security measures to protect personal information in our custody and control against unauthorized access, use, modification and disclosure, and accidental loss, destruction and damage. For example, we use standard, industry-wide, commercially reasonable security practices such as encryption, firewalls and SSL (Secure Socket Layers) as well as physical safeguards at the locations where data is stored. However, as effective as encryption technology is, no security system is impenetrable. We cannot guarantee the security of our database, nor can we guarantee that information you supply will not be intercepted while being transmitted to us over the Internet. Any transmission of information by you to OpenMobile is at your own risk. Where you have chosen a password that allows you to access our Website or App you are responsible for keeping this password confidential. We strongly recommend that you do not share your password with anyone.
Our employee laptops are secured with strong passwords. We ensure that our employees are trained and informed on best practices and secure handling of your personal information, and only have access to this information when required to perform their duties. Our physical office premises are also secured with locks and keycodes.
The third-party vendors with whom we engage for specific tasks are required to have certain safeguards in place that comply with industry standards. They are also contractually bound not to disclose or use the information for any other purpose.
Third-party links: Our Website or App may contain links to other sites that we do not own or operate. Except as provided in this Privacy Policy, we will not give any of your personal information to these third parties without your consent.
We provide links to third-party websites as a convenience. These links are not intended as an endorsement of or referral to the linked websites. The linked websites have separate and independent privacy statements, notices and terms of use, which we recommend you read carefully. We do not have any control over such websites, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose, secure and otherwise treat your personal information.
11. How Do I Correct The Personal Information You Have On Me?
You may request that we correct the personal information we have about you by signing into your account. You may also contact us at support@openmobile.ca to review the information and request changes.
12. How Do I “Opt-out” Of Certain Communications?
To opt-out of receiving certain communications that you sign up for, such as newsletters or promotional offers, simply click on the unsubscribe link located at the bottom of the communication. You may also adjust your preferences in your account to unsubscribe. Please note your unsubscribe request may take several days to process.
13. Policy Updates
This Privacy Policy and other product or service specific policies may change from time to time, in accordance with applicable laws. We will notify you of these changes by posting the updated policy on our website. We may also notify you by sending you an e-mail or by any other reasonable means such as an in-App notice.
We encourage you to review our Privacy Policy periodically.
14. How Do I Report A Concern About My Personal Information?
If you wish to raise a concern or even say something really nice about our privacy practices, you can contact us at info@openmobile.ca.
15. How To Make A Complaint?
We strive for Member satisfaction. If we are not able to address your privacy concerns to your level of satisfaction, you may contact the Office of the Privacy Commissioner of Canada:
Office of the Privacy Commissioner of Canada
30, Victoria Street
Gatineau, Quebec
K1A 1H3
Toll-free: 1-800-282-1376
Phone: (819) 994-5444
TTY: (819) 994-6591