What is personal information at Mondofix Inc.

“Personal information” is a combination of the following elements that may, individually or in combination, identify you as an individual or reveal personal information about you as an individual. Examples of types of personal information that we may collect from you include, but are not limited to:

• your name
• your address
• your telephone number
• your e-mail address
• information you enter into text fields
• paper forms that you may fill out or may be retained about you to identify yourself
• anonymous browser information and cookies etc.

YOUR CONSENT

BY SUBMITTING YOUR PERSONAL INFORMATION TO US (DIRECTLY OR INDIRECTLY), YOU ARE CONSENTING TO THE COLLECTION AND PROCESSING OF YOUR PERSONAL INFORMATION AND TO OUR USE OF YOUR PERSONAL INFORMATION AND ANY RELATED INFORMATION IN THE MANNER DESCRIBED IN THIS PRIVACY POLICY, INCLUDING THE TRANSMISSION TO, AND STORAGE AND PROCESSING OF YOUR PERSONAL INFORMATION BY THIRD PARTIES OUTSIDE CANADA. IF YOU ARE SUBMITTING PERSONAL INFORMATION OF THIRD PARTIES TO US, YOU WARRANT AND REPRESENT YOU HAVE THEIR CONSENT TO PROVIDE THEIR PERSONAL INFORMATION TO US AND YOU WILL INDEMNIFY US AND HOLD US HARMLESS FROM AND AGAINST CLAIMS BY SUCH INDIVIDUALS RELATING TO OUR PROCESSING AND USE OF SUCH PERSONAL INFORMATION WITHIN THE TERMS OF THIS PRIVACY POLICY.

CONSENT

When we collect, use or disclose your personal information we will do so with your consent. We obtain your consent before or at the same time we collect your personal information. In some instances, however, we may seek your consent after we have collected your personal information if we wish to make an additional use or disclosure of your personal information where we do not already have your consent for that new use or disclosure.

Depending on the circumstances, your consent may be express or implied. Express consent would arise if you specifically consented to a particular dealing in your personal information. Express consent can be given orally, electronically or in writing.

Implied consent can be inferred from the circumstances and, in particular, where the uses and disclosures are readily apparent at the time we collect the personal information. For example, if you send us an email requesting certain information, we will use the email address in your email to send the requested information to you without asking you if we can use the email address for that purpose; your consent will be implied in those circumstances. As well, we will assume your consent to the collection, use or disclosure of your personal information for a particular purpose if you voluntarily provide the information for that purpose.

By providing personal information in connection with the Services and the Sites, we will assume that you have consented to the collection, use and disclosure of personal information in accordance with the terms set out in this Privacy Policy unless you inform us otherwise.

HOW WE COLLECT YOUR PERSONAL INFORMATION

1. Cookies

Our website uses “cookies”. A cookie is a small text file sent to your browser’s files for our reference. No one else can read this file. The only way we use cookies is to remember unidentifiable information like language preferences.

If you do not wish to receive cookies, we have implemented a cookie management feature on our websites which allows visitors to enable only the cookies of their choice.

We may also use cookies to troubleshoot how the Sites operate, and for internal analysis of how site visitors use our Sites.

You can instruct your browser, by changing its options to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may limit the functionality we can provide when you visit and use the Sites.

2. Clickstream Data

During your visit to our sites, we may record choices you have made and use this to provide more customized content or advertising. The data does not identify you and is not retained after your visit. This is sometimes called “clickstream” data. If we do market research, studies, or polls in any area, that will only be reported in aggregate format.

We may collect information about your location if you provide your address or postal code or we may approximate your location based on your IP address. If you provide our mobile applications access to location services on your device, we and our third-party providers may collect location data through GPS, Wi-Fi, wireless network triangulation or other similar methods.

3. Voluntarily Provided

We will collect personal information that you voluntarily provide to us.

When you interact with us through certain activities on the Sites or in connection with the Services, such as subscribing to our mailing lists, inquiring about a franchise, making an appointment, and sending messages through the Sites, we may ask you to provide personal and other information. In order to engage in such activities, you will be required to provide information that lets us know the specifics of who you are, such as your first name, last name, e-mail address, phone number, and other information.

If such information is required to provide Services to you or where it is optional for you to engage in these activities, then if you do not provide the mandatory information with respect to a particular activity, you may not be able to engage in that activity and we may not be able to assist you in connection with our Services or fulfill the purpose for which you contacted us. You may also limit your ability to use all or a portion of the Sites.

HOW WE COLLECT YOUR PERSONAL INFORMATION

In Accordance with Your Consent. We may use your personal information in accordance with the consents that you have provided, whether explicit or implied, including as may be set out in this Privacy Policy.

4. In Connection with Our Business

We may use your personal information for particular activities, including, without limitation, responding to your inquiries, customer service, providing Services to you, payment processing, collections, marketing and research, sharing your stories that you provide to us, developing and displaying content tailored to your interests, processing your franchise application and contacting you regarding franchise opportunities, providing promotional and other information to you, and contacting you regarding administrative notices or to solicit feedback on your experience with us or one of our franchisees. In particular, set out below are certain circumstances where we may use your personal information without obtaining any further consent:

• using identification information and contact information, such as your name and e-mail address to provide information about us, the Services and Sites when you request that information;
• using identification information and contact information, such as your name and e-mail address so that we can identify you and deliver the Services that you request and to communicate with you regarding those Services;
• using payment method preferences and related financial information that you provide to us so that we can obtain payment for the Services that you request;
• using information relating to your preferences so that we are able to deliver our Services and in connection with the Sites, to you in accordance with those preferences;
• using relationship information such as your service requests, instructions, comments and feed back to assist us in delivering Services, including in connection with the Sites, in accordance with your wishes;
• using personal information for the purpose for which it was provided and certain other activities that are reasonably ancillary to that purpose. For example, if you request a Service from us, we may send you follow up correspondence to ask you about your satisfaction with the Service. Further, we may store your response and use the information in the response when we provide Services to you in the future;
• using your e-mail address to provide you with information about new features or enhancements to the Services and the Sites;
• analyzing how personal information is being used to assist us in developing and enhancing our Services and the Sites; and
• analyzing how browser session information is being used to assist us in conducting market analysis and strategic planning like assisting in the development of new products or services, research; advertising; and to identify trends and changes.

We may use your location information to provide personalized content and advertising, to enhance your experience with the Sites and Services, to allow you to view promotions and products available to you based on your location, to assist us with analytics, and to improve the effectiveness of our Sites and Services.

We may use your IP address and similar web site use information to: (i) help diagnose problems with the Sites, administer and improve the Sites, and measure the use of the Sites; (ii) identify the type of web browsers used, the pages viewed, the web sites from which a visitor found the Sites, and the search terms and search engines used to find the Sites; and (iii) gather other web analytics information relating to visitors’ use and navigation of the Sites. This information does not identify you personally. On occasion we may aggregate this data with data on the pages visited by other users to track overall visitor traffic patterns and provide this aggregate information to vendors, business partners, or affiliates.

WITH WHOM WE SHARE OR DISCLOSE THE PERSONAL INFORMATION WE COLLECT

With Your Consent, we may disclose your personal information that you have provided, whether explicit or implied, including as may be set out in this Privacy Policy.

5. In Connection with Our Business

We may disclose your personal information for particular activities, including but not limited to, providing Services to you, payment processing, collections, marketing and research, sharing your stories that you provide to us. In particular, set out below are certain circumstances where we may disclose your personal information without obtaining any further consent:

• In the event we transfer or are considering transferring control of any or all of our operations or services to another organization, we reserve the right to transfer and disclose your personal information to that organization. However, we will require that the organization agree that it will be similarly bound by the provisions of this Privacy Policy and that it will only use and disclose personal information as we are similarly entitled under this Privacy Policy;
• In the event we amalgamate with another organization, we reserve the right to permit that amalgamated organization to continue to use and disclose your personal information. However, we will require that the amalgamated organization agree that it will be similarly bound by the provisions of this Privacy Policy and that it will only use and disclose personal information as we are similarly entitled under this Privacy Policy;
• We may engage certain third-party service providers. Those service providers may provide services to us to assist us in our activities, for example for booking appointments or providing estimates when you make such a request through our websites. Other service providers may provide services directly to you at our request. As such, it may be necessary to disclose your personal information to these service providers. Subject to the exceptions described in the section entitled Third Party Organizations below, we will take steps to ensure that these service providers will only use and disclose your personal information as necessary to provide the services and that they will adhere to the terms of this Privacy Policy and their contractual obligations with us; and,
• We may work with other organizations towards some common purpose consistent with our business objectives. In that case, it may be necessary for us to disclose your personal information to these organizations. However, we will require that these organizations agree that they will only use and disclose your personal information as necessary for the common purpose and that they will adhere to the terms of this Privacy Policy.

OTHER USES AND DISCLOSURES

6. Permitted by Law

Privacy law permits or requires the collection, use and disclosure of personal information without the knowledge or consent of the individual in certain circumstances. We reserve the right to collect, use and disclose your personal information in these circumstances without your knowledge or consent, including: (a) in response to a subpoena, search warrant, court order, or other legal process or request; or (b) to protect and defend our rights or property or those of our related entities, franchisees, or business partners, or others.

7. Safety and Security

We may collect, use and disclose your personal information as needed to protect the safety and security of our business and assets, including our computer systems, software, personal information and data, and to protect our property and our rights and those of third parties.

8. Monitoring Use

We may monitor your use of the Sites to ensure the proper use and operation of the Sites and your compliance with any terms of use related to the Sites or other related agreements and in connection with the protection of the security and safety of our computer systems, software, personal information and data.

Other than as set forth in this Privacy Policy, we do not sell, transfer, share or disclose personal information to third parties.

We do not sell the personal information we obtain through our websites

To support our commitment to the protection of our customers and potential customers personal information we are transparent about our practices to not engage in selling of personal information.

CHILDREN’S ONLINE PRIVACY PROTECTION

Our Sites are not directed to children under the age of 13 and we will not knowingly collect personal information from children under the age of 13 on our Sites. If we become aware that we have inadvertently received personal information from a child under the age of 13 on our Sites, we will delete the information from our records.

HOW WE SAFEGUARD THE PERSONAL INFORMATION WE COLLECT AND USE

We take the security of personal information very seriously.

We use physical, technical and organisational security measures to protect the Personal Information we have under our control against accidental or intentional manipulation, loss, destruction or against access by unauthorised persons.

As some of our business partners may be outside of Canada, we may transmit your Personal Information to third parties outside Canada for storage or processing. We employ technical and organizational measures to ensure your personal information is subject to appropriate safeguards and that it is processed and secured in accordance with applicable laws. We will conduct the appropriate transfer risk assessments to identify the appropriate legal, technical and administrative measures our third-party service providers need to put in place and we will implement continuous monitoring to ensure these safeguards remain in place for the duration of our business relationship with them.

For Canadian data, the storage location is either in Canada or in the EU and is subject to GDPR.

We make commercially reasonable efforts to ensure that Personal Information collected is protected against loss and unauthorized access. Access to Personal Information is restricted to selected employees and representatives of Mondofix Inc. In addition, we employ generally accepted information security techniques, such as firewalls, access control procedures and cryptography, to protect Personal Information against loss and unauthorized access. Despite the measures outlined above, no method of information transmission or information storage is 100% secure or error-free and unfortunately, we cannot guarantee absolute security. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any Personal Information that you provided to us has been compromised), please contact us immediately using the contact information in the “How you can contact us” section below.

OUR RELATIONSHIP TO OTHER WEB SITES

The Sites may contain links to other web sites. If you visit one of these other web sites, we encourage you to review the privacy policy on that web site. We are not responsible for the policies and practices of other web sites, and any information you submit to those web sites is subject to their privacy policies.

We may have functionality on the Sites that is provided, in whole or in part, by a third-party service provider. You can usually identify such third-party functionality by the use of a trademark not owned by us on or near the functionality. In that case, when you use the functionality, you become subject to the terms of use and privacy policy of this third party in addition to the Privacy Policy and Terms of Use of our Sites. In some cases, you may need to visit that party’s web site and locate the terms of use and privacy policy.

THIRD PARTIES HOSTED BY OUR SITES

We use certain third-party service providers that collect, use and disclose personal information for their own purposes.

For example, we use different tools such as “Google Analytics” to collect information about use of this site. Google Analytics and other tools we use collect information such as how often users visit this site, what pages they visit when they do so, we use the information we get from Google Analytics and other tools only to improve this site. We have configured the analytic tool used to only collect the IP address assigned to you on the date you visit this site, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics or other tools with personally identifiable information. Although analytic tools may plant a cookie on your web browser to identify you as a unique user the next time you visit this site., Google’s ability to use and share information collected by Google Analytics about your visits to this site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. You can prevent Google Analytics from recognizing you on return visits to this site by disabling cookies on your browser.

PRIVACY RIGHTS AND REQUESTS AND HOW TO CONTACT US

You may have rights under applicable laws concerning personal information we have collected about you, which may include the right to access your personal information we have, to ask us to delete, correct, or restrict the use of your personal information, to withdraw your consent to our use of your personal information, to ask how we have used your personal information, to ask whether we have shared your personal information, and to whom we have shared your personal information. We will honor your rights to the extent required by us under applicable laws.

All requests relating to your personal information and any concerns you have relating to our privacy practices can be submitted one of the following ways:

Please clearly state what information you are requesting and any other requests you are making.

We will respond to your requests within the time limits established by applicable law or within a reasonable time if no time limit is established by applicable law, once we have verified you are the originator of the request.

If you contact us requesting that we take action regarding your personal information or regarding concerns you have relating to our privacy practices, such requests must be made in writing or otherwise be verifiable as originating from you. In order to protect your information and because people may have the same name, we will only provide or delete personal information once we are able to reasonably verify your identity as the requestor.

For your protection, we may ask you for additional information to verify your identity. In most cases, we will provide the information you request and correct or delete any inaccurate personal information you discover. We reserve the right, however, to limit or deny your request to the extent permitted by applicable law, including if: (a) complying with the request may present a threat to the personal safety, property, or rights of any other person or organization; (b) complying with the request may lead to a violation of applicable laws or regulations; (c) we are not required to comply with the request because of a legal rule or exception; or (d) you have failed to provide us with sufficient evidence to verify your identity. We will not delete personal information if that personal information is related to an ongoing transaction. Even after a request, we may also keep personal information where necessary to comply with applicable laws or where necessary to protect a legal right or fulfill a legal obligation or where we are not otherwise required by law to delete the information.

Currently Alberta, Quebec, and British Columbia have substantially similar privacy laws as the Federal Private sector Privacy Law PIPEDA.  Ontario, New Brunswick, and Newfoundland and Labrador have each enacted a law that is substantially similar in its treatment of personal health information.  PIPEDA applies in all other respects in these provinces.

If you are not satisfied with the answers to your inquiry and you would like to submit a complaint, you can contact:

The Office of the Privacy Commissioner of Canada (PIPEDA)

Website: www.priv.gc.ca

This website contains extensive contact information for all provincial privacy regulators and ombudsmen.  It is kept up to date and should be your first source of regulatory contact information.

General Inquiries: Toll-free: 1-800-282-1376

Phone: (613) 947-1698

Fax: (613) 947-6850

TTY: (613) 992-9190Hours of service are from 8:30 a.m. to 4:30 p.m.

Québec CAI Contact Information

https://www.cai.gouv.qc.ca/a-propos/nous-joindre/

Alberta

https://oipc.ab.ca/about-us/contact-us/

British Columbia

https://www.oipc.bc.ca/about/contact-us/

New Brunswick

https://ombudnb-aip-aivp.ca/about-us/contact-us/

Newfoundland and Labrador

https://oipc.nl.ca/contact

How Long We Keep Personal Information

Subject to applicable law, we retain personal information in accordance with our records retention policy or program. We will retain personal information for the length of time necessary for the purposes for which we collected the personal information or to demonstrate we have fulfilled our duties or obligations, or for retention periods required by applicable law or in which claims may be made or the existence of legal proceedings.