Privacy Policy
Mobiroo Inc. (“Mobiroo”) is committed to respecting your privacy and protecting
your Personal Information. This Privacy Policy explains our practices on our website
(including mobile website) (“Website”) and related services (“Services”)
regarding collection, use and dissemination of your Personal Information. “Personal
Information” means information about an identifiable individual, but does
not include the name, title, business address or telephone number of an employee
of an organization.
Accountability
Mobiroo is responsible for maintaining and protecting the Personal Information under
our control. Accountability for this function within our organization is held by
Mobiroo’s Privacy Officer (who can be contacted at the address below).
Where we disclose or transfer Personal Information to related companies or third
party service providers as set out in the Privacy Policy, we use contractual or
other safeguards to provide a comparable level of privacy protection for Personal
Information.
Information Collected and Its Purpose
Mobiroo will identify to an individual the purposes for which Personal Information
is collected at or before the time the information is collected. We will only collect,
use and disclose Personal Information from our customers and employees for the following
business reasons:
- to provide you with our goods and services;
- to determine which of our products and related services meet the needs of individual
customers;
- to develop, enhance, market or provide products and services;
- to manage and continually develop our businesses and operations, including personnel
and employment matters;
- to investigate and detect potentially fraudulent transactions; and
- to meet legal and regulatory requirements.
Mobiroo collects and uses Personal Information for providing promotions and offers
from us and our business partners only after receiving express permission to do
so. We will advise you in advance if Personal Information is to be collected or
used for our business partners; such collection and use will be by and for such
business partners and subject to their privacy policies, and you should consult
such privacy policies prior to consenting to such collection or use. We may also
sell, transfer and disclose your Personal Information as part of a business divestiture,
sale, merger, reorganization, or acquisition of all or a part of our business.
If we want to use Personal Information for a purpose other than what was identified
at the time the Personal Information was collected, then we will obtain the prior
consent of the individual to that additional use.
Personal Information collected may include your email address, name and responses
to survey questions. Information such as survey responses will not be directly associated
with you and will only be provided to our business partners on an anonymized basis.
We may use your email address to send you your credentials or other account information
for future reference. We may also use this to notify you of future software updates
for apps that you download as they become available.
We may passively collect your mobile device information, such as PIN, IMEI number,
device model, carrier network as well as information about your bandwidth usage
of apps downloaded from the Website, such as the date and time of each usage, time
spent using an app, clicks on advertisements, statistics, etc. This information
will only be used to generate aggregate usage statistics. PIN, IMEI number and device
information will be used to register each device as an active device. Unless otherwise
indicated to you in advance, such information will only be used for support-related
requests and will not be shared with any third parties, except for certain developers
or distributors who will be contractually obligated to limit its use to authenticating
or supporting their app, as otherwise required by law, or pursuant to a separate
agreement or notification between you and the developer or distributor.
Mobiroo also routinely collects anonymous, non-Personal Information through our
Web servers. This is information that is not associated with or traced back to a
specific individual. Gathered electronically, this information includes the type
of Web browser used, the level of encryption a browser supports and the Internet
Protocol address. This information may be used for research and analytical purposes,
to examine how the Web site is being used and to determine how it can be improved.
We also use “cookies” to improve our service to you. A cookie is a small piece of
information that is sent to a computer when accessing a Web site. We may use cookies
on the Website to allow you to gain access to a document you requested prior to
being signed in, and a persistent cookie to store your encrypted user ID and password,
so that you will not be required to type it in each time that you access the Website.
This cookie will only be stored if you click on “Remember my sign-in information”
on the Website.
Limiting Use, Disclosure and Retention
We will only collect the amount and type of Personal Information which is necessary
for our identified purposes or as required by law, and we will only collect Personal
Information by fair and lawful means.
Access to Personal Information is limited to Mobiroo employees and suppliers who
require access for business purposes.
From time to time, we transfer Personal Information for administrative or processing
purposes to related companies or third party suppliers, or to assist us in communicating
with individuals (such as for surveys and mail distribution, or for technical support).
These related companies or suppliers may be in another jurisdiction. We may also
disclose or transfer Personal Information to third parties retained to assist in
the administration and investigation of a claim reported to us. In these cases,
we use contractual or other safeguards to ensure protection of Personal Information.
Our suppliers are contractually obligated to keep the information confidential,
to use the information only for the purpose requested by Mobiroo and to destroy
the information when it is no longer required. As a result of the use of related
companies and suppliers, your Personal Information may be securely used, stored
or accessed in the USA or other countries and may be subject to the laws of those
countries. For example, Personal Information may be disclosed in response to valid
demands or requests from government authorities, courts, or law enforcement in these
countries.
When Personal Information is no longer required to fulfill the purpose for which
it was collected, it will be destroyed, erased, or made anonymous, provided there
are no legal requirements for its continued retention.
Accuracy
We will use reasonable commercial efforts to ensure that Personal Information is
as accurate, complete, and up-to-date as is necessary for the purposes for which
it is to be used, including information that is transferred to related companies
and suppliers for administrative and processing purposes.
Safeguarding Personal Information
Personal Information, whatever its form, will be protected by commercially reasonable
security safeguards appropriate to the sensitivity of the information to protect
Personal Information against loss or theft, as well as unauthorized access, disclosure,
copying, use or modification.
Mobiroo employees will be made aware of the importance of maintaining the confidentiality
of Personal Information, and we will exercise care in the disposal or destruction
of Personal Information to prevent unauthorized parties from gaining access to it.
We will safeguard Personal Information by physical measures (for example, locked
filing cabinets and restricted access to offices), organizational measures (for
example, by continued employee training and limiting access on a “need-to-know”
basis), and technological measures (for example, by the use of passwords and encryption).
Access to Personal Information
Individuals may request a copy of their Personal Information held at Mobiroo by
submitting a written request to the Chief Privacy Officer at the address below.
If you feel the information we have about you is inaccurate, you may request that
it be reviewed and, if inaccurate, changed, by contacting the Chief Privacy Officer.
An individual’s written request for access to Personal Information will be answered
within a reasonable time and at a reasonable cost. Acceptable proof of identification
is required before proceeding with the request.
If an individual successfully demonstrates the inaccuracy or incompleteness of Personal
Information, we will amend the Personal Information. If a challenge is not resolved
to the satisfaction of the individual, we will document the substance of the unresolved
challenge. The amended information or the existence of the unresolved challenge,
as the case may be, may be transmitted to third parties having access to the information
in question.
Requests for access to the Personal Information we hold about an individual may
be refused if permitted or required by law. In such a case, the reasons for denying
access will be provided to the individual upon request. Exceptions may include:
information that contains references to other individuals or contains confidential
commercial information which cannot be severed from the record; information collected
in the course of investigating a breach of an agreement or in the course of a formal
dispute resolution process; and information that is subject to solicitor-client
privilege.
Challenging Compliance
individual can challenge compliance with this Privacy Policy by providing written
details of the challenge to the Chief Privacy Officer. Address for service is as
follows: privacyofficer@mobiroo.com
All written complaints will be investigated. If we find a complaint to be justified,
we will take all appropriate measures, including, if necessary, amending our policies
and practices. A complainant shall be informed of the outcome of the investigation
regarding his or her complaint.
We encourage the use of our internal information and resolution process to resolve
a complaint. However, an individual may also seek advice from the Office of the
Privacy Commissioner of Canada at 1.800.282.1376 or
info@privcom.gc.ca and, if appropriate, file a written complaint with that office.