This policy has been designed to comply with the Personal Information Protection and Electronic Documents Act (“PIPEDA”) and describes:
- the types of Personal Information we collect;
- how your Personal Information is used;
- how your Personal Information may be shared;
- the steps we take to ensure your Personal Information is handled in a safe and secure manner;
- how you can access the Personal information we retain and how to keep it accurate; and
- how to contact us with any privacy concerns.
Collecting Your Personal Information
Depending on which services you use, we collect different kinds of information from or about you. Some examples of how and when we collect Personal Information follow:
We collect information and content you provide when you use our services, including when you sign up for an account, create or share, and communicate with others. Accordingly, we will collect information establishing your identity (such as your name, email address, mobile telephone number, and your city/province of residence) and information to authenticate your identity (i.e. username, password and account information).
We collect Personal Information about how you use our services, and to offer you additional products and services we believe you might be interested in.
We collect information about the individuals and groups you are connected with, such as the people you communicate with most. We also collect contact information you provide if you upload or import this information from a device.
We collect information from or about the computers, phones, or other devices you use to access our services, such as a device’s operating system, hardware version, battery and signal strength, and device identifiers; device locations through GPS, Bluetooth, or WiFi signals; and connection information such as browser type, time zone, mobile phone number and IP address.
When you use our services, and while you are our current or former user, or act on behalf of one, we may collect Personal Information about you directly from you, from your interactions with us, and from other sources outside our organization or any other source, or as permitted or required by law. You authorize the collection of Personal Information, and where applicable, you authorize outside sources to provide us your Personal Information.
How we obtain your consent
It is important to understand the various ways in which we obtain your consent to collect, use and share your Personal Information. Express consent may be obtained verbally, electronically or in writing. Implied consent may be obtained through your use of our services, or when you approach us to obtain information, or inquire about services from us.
We will not make your consent a condition of obtaining our services, unless it is reasonably or legally required, and we will clearly indicate when this is the case.
Using Your Personal Information
We may use this Personal Information for purposes including to:
- provide you with services you have requested;
- personalize content;
- provide suggestions to you;
- send you marketing communications, and communicate with you about our services;
- respond to you when you contact us, and verify your identity when you contact us or when we contact you;
- improve our advertising systems so we can show you relevant ads and measure effectiveness and reach;
- help verify accounts and activity, and promote safety and security such as by investigating suspicious activity or violations of our terms or policies;
- market a product or service, either directly or indirectly;
- determine your eligibility for some of our services and offer them to you; and
- comply with legal, regulatory, governmental and contractual requirements.
We may also use your Personal Information for other purposes with your consent, express or implied, or as permitted or required by law.
If for any reason your information is required to fulfill a different purpose then that of your original intent, we will ask for your consent before we proceed.
Sharing Your Personal Information
People use our services to connect with, and share with others. When you sign up, share and communicate using our services, in some cases, people you share and communicate with may download or re-share your content.
We work with some third party companies who help us provide and improve our services, such as providing technical infrastructure services, or who use advertising or related products, which makes it possible to provide our services to you, in some cases, free of cost. We may use all of the information we have about you to show you relevant ads.
We may share your Personal Information with our employees, agents, service providers and any other entities that perform services on our behalf (collectively, “service providers”). You acknowledge that some of our service providers may be located outside of Canada and as such your Personal Information may be accessible to governmental, national security and regulatory authorities in accordance with the laws of these jurisdictions.
We may share your Personal Information with prospective employers and other persons, organizations or agents to whom you have provided consent directly.
We may share your Personal Information in response to a court order, search warrant or other demand or request we believe to be valid.
We may share your Personal Information to satisfy legal, audit, insurance, self-regulatory and regulatory requirements applicable to us.
We may share your Personal Information with any person or organization, including an investigative body, in order to prevent, detect or suppress financial abuse, fraud, criminal activity, or to assist us with any internal or external investigation into potentially illegal or suspicious activity or to manage, defend or settle any actual or potential loss.
We may otherwise share your Personal Information with your consent or knowledge, or where permitted or required by law.
We do not sell the names or other Personal Information of our users. We do not disclose the names or other Personal Information of our users without consent, unless required or permitted by law.
Additional Collection, Use and Sharing of Your Personal Information
We may verify your Personal Information on an as needed basis.
We may monitor and/or record any communications between you and us for accuracy, service quality, training and security purposes, our mutual protection and to enhance our customer service experience. We may communicate with you through various channels including telephone, computer, mail or applications or by other electronic means, using the contact information you have provided.
Protecting Your Personal Information:
We have implemented safeguards to protect your Personal Information at a level appropriate to the sensitivity of the information. Authorized employees, representatives, and agents will have access to your Personal Information in order to perform their job functions.
Retaining Your Personal Information:
You can delete your account at any time. We will retain your Personal Information only as long as it is required for the reasons it was collected. This may include customer service, legal or regulatory needs that require us to keep your Personal Information beyond the end of your relationship with us. When your Personal Information is no longer required, we will securely destroy it or convert it to anonymous form.
Accessing and Updating Your Personal Information:
You are responsible for advising us of any inaccuracies or changes to your Personal Information (such as a change of email address, telephone numbers, current email address etc.). If any of your Personal Information changes or you discover inaccuracies in our data, you are required to advise us so we can update our records.
Subject to contractual and legal restrictions as well as reasonable notice, you may request access to or correction of the Personal Information we hold about you at any time by submitting a written request to the designated individual(s) named below under the heading “Contact Us”. We will endeavour to respond to your access request within 30 days of receiving all necessary information, or advise you if we require additional time. We may not be able to provide you access to your Personal Information in certain situations (e.g., if disclosing the information would reveal information about a third party). If this is the case, we will inform you of the reasons that we were unable to provide you access.
Respecting Your Privacy Preference:
Subject to legal, regulatory and contractual requirements, you can refuse or withdraw your consent to our collection, use or disclosure of your Personal Information at any time by giving us reasonable notice. Depending on the circumstances, however, withdrawal of your consent may prevent us from providing you or continuing to provide you with some services or information that may be of value to you. We will act on your instructions as quickly as possible but it may take some time for our records to reflect your choice.
Participation in customer research and surveys:
From time to time, we may ask you to participate in customer research or surveys that help us to improve our offer and better understand your needs. You may opt out of participating.
To request access to, or correction of, your Personal Information, to ask questions about our privacy policies or to refuse or withdraw your consent to our use of your Personal Information for purposes outlined in this policy, you may send in a written request or contact us at:
ROSEMARIE AMI SEABORN
895 Don Mills Road Suite 900
Two Morneau Shepell
Toronto, ON M3C 1W3
Please note that requests for access must be in writing.
Changing this Policy:
We may amend this policy from time to time to take into consideration changes in legislation or other issues that may arise. Our amended policy will be posted on onepinoy.com, and will be effective at the time it is posted. We encourage you to review the policy whenever you interact with us to stay informed about our information collection and use practices, as your continued use of our services or provision of Personal Information after changes have been made to the policy constitutes your acceptance of those changes.