What personal information do we collect?
- We may collect personal information directly from users of our website https://www.squirrelsystems.com , and app (the “Sites”), software or services, including name, date of birth, address, phone number, email, emergency address, gender, age, profile photo and/or video, authentication information, location, RF card information, device and mobile phone IP address information, device MAC address information, and log information. Users may also provide additional information by choosing to fill out free-form fields on our Sites if available.
- By using our Sites, software, or services, you are choosing to provide us with your personal information and you acknowledge and consent to the processing of your personal information in Canada, the United States, and any other jurisdiction in which our third party service providers (as described herein) process information.
Why do we collect personal information and how is it used?
- We collect personal information to facilitate the use of our Sites, software and services.
- We also use personal information for research and marketing purposes.
- The personal information that we collect about devices and the use of our Sites is used in an aggregate and de-identified form to evaluate and improve our services.
Is personal information shared or disclosed?
- We share your personal information with the merchants using Squirrel to power their business.
- We also may use certain third party service providers who may have access to the information we collect.
- We may also disclose or share personal information for fraud prevention, and other permitted disclosures under applicable law.
How do we protect personal information?
- We have implemented safeguards to protect personal information under our control, and regularly review our practices to ensure they align with reasonable practices appropriate to the level of sensitivity of the information, in order to safeguard personal information against loss or theft, unauthorized access, alteration or disclosure.
What are the risks?
- Although we take steps to safeguard the personal information under our control, “perfect security” does not exist online or elsewhere. In particular, we cannot guarantee the security of information posted or transmitted using our Sites or via email. It is possible that third parties may unlawfully intercept or access such information.
What are your choices?
- You may request access to and review of your personal information in our possession, subject to certain limitations.
- You may also request that we change or delete your personal information in our possession. We will always work hard to comply with such requests, subject to certain limitations.
- You may withdraw your consent to our use of your personal information at any time provided you also cease using the Sites at the same time.
What else should you know?
- We may use cloud services provided by third party service providers to store the personal information that we collect, and other service providers outside Canada or the United States. This means that your information may be transferred to, or stored in, another country and accessible to foreign courts, law enforcement and national security authorities.
- You can contact us with questions, complaints or for to access your personal information.
Last Updated as of May 15th, 2022
This Policy describes our practices with respect to how we may collect, use, disclose, retain, dispose and otherwise process (collectively, “process”) and how you may correct, update and access your personal information that you provide as a user of (a) our website and apps (the “Sites”), (b) any front-end software we provide you that interacts or interfaces with the Sites (the “Software”), excluding third party software that may interact with the Sites or the Service as defined below, and (c) the services we provide through the Sites and/or the Software (collectively, the “Service”).
Our Sites and Software may contain links to other apps, 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 Internet resource. We have no responsibility or liability for, or control over, those other Internet resources or their collection, use and disclosure of your personal information. We encourage you to read the privacy policies of those other Internet resources to learn how they collect and use your personal information.
If you do not consent to the processing of your personal information in accordance with this Policy, please do not access or continue to use any of the Sites, Software or Service or otherwise provide any personal information to us.
- Personal Information
For the purposes of this Policy, “personal information” is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with an identifiable individual, including but not limited to an individual’s name, home address, telephone number, social insurance number, gender, income and family status, except any other information otherwise exempted by the applicable laws of Canada and other jurisdictions. For example, in Canada and some laws in the United States, personal information does not include any business contact information that is processed solely to communicate with that person about his or her employment or profession.
When you use our Sites, Software or Service, we may collect the following personal information from you:
- Identifiers such as first and last name, email address, mailing address, location of residence (city/province/country), phone number, social insurance number, family status, profile photo and/or video, username, account number and password. We source this information directly from you or indirectly from you (e.g., from observing your actions on our Sites, Software or Service). We disclose identifiers for business purposes to our internet service providers, merchants, and administrative service providers;
- Characteristics of protected classifications and demographic information such as age or gender. We source this information directly from you. We disclose this information to merchants;
- Commercial information such as records of products purchased, obtained, considered, or other purchasing or consuming histories or tendencies. We source this information directly from you or indirectly from you. We disclose this information for business purposes to internet service providers, merchants, administrative service providers, and payment processors;
- Billing information as appropriate such as credit card number and billing address. We source this information directly from you. We disclose this information for business purposes to merchants;
- Professional information such as name of employer, occupation, location of occupation, income, and insurance. We source this information directly from you. We disclose this information for business purposes to internet service providers and administrative service providers;
- Technical information such as authentication information, device MAC address information, device and mobile phone IP and IMEI address information, and browser and log information. We source this information indirectly from you (e.g., from observing your actions on our Sites, Software or Service). We disclose this information for business purposes to internet service providers, merchants, administrative service providers, and payment processors; and
- Inferences drawn from other personal information, which may include a profile reflecting a person’s preferences, interests, and characteristics. We source this information directly or indirectly from you (e.g. from observing your actions on our Sites, Software or Service). We disclose this information for business purposes to internet service providers, merchants, administrative service providers, and payment processors.
Your personal information may also be collected when:
- You register for an account with us;
- You connect with us through social media;
- We collect cookies and other tracking information through your use of the Sites, Software or Service;
- We collect data from third parties or publicly available sources.
You have choices about the information we collect.We encourage you to not provide us with any personal information beyond what is necessary and as requested by us. When you are asked to provide personal information, you may decline. However, if you choose not to provide information that is necessary, you may not be able to use our Sites, Software or Service.
Cookies and Log Files
Our Sites may use “cookies” and similar technologies like single-pixel GIFs and web beacons. A “cookie” is a text file that is sent to your computer or device and from your computer each time you use the site. Cookies can track how and when you use our Sites and which site you visited immediately before. A cookie does not damage your system and identifies your browser.
- Facebook Analytics: We also use Facebook Analytics to measure your use of our Service, tailor our Service to your interests, and improve our products and Service. Please note, Facebook can connect this data with your Facebook account and use it for its own advertising purposes, in accordance with Facebook’s Data Policy which can be found at https://facebook.com/about/privacy/. Please click here if you would like to withdraw your consent.
If you do not wish to receive cookies, you may be able to disable them. Although this may provide you with enhanced anonymity, it may affect the functioning of our Sites. For more information and to opt-out, visit the Network Advertising Initiative here, or the Digital Advertising Alliance here. Although our website currently does not respond to do not track browser headers (see the Do Not Track Disclosure section below), you can limit tracking through these third -party programs and by taking the other steps discussed
Information about Minors
The Sites are intended solely for users who are not minors (13 years of age or older). We do not knowingly collect personal information about any minor. No such minor, nor any parent or guardian as it relates to such minor or any other user of the Sites or Software, should submit personal information of a minor to us through the Sites, Software or otherwise for any reason and under any circumstances.
- Purpose for Which Personal Information is Processed
We may process your personal information for the following purposes (the “Purposes”):
- To verify and authenticate your identity;
- To de-identify your personal information and create aggregated data;
- To allow us to use the services of third party services such as:
- Microsoft Azure cookies to access our cloud services; and
- Apple push notification services and Firebase Cloud Messaging which allow us to keep you informed with timely and relevant content relating to the Sites, whether the Sites is running in the background or inactive.
- To ensure that the Sites, Software and Service are optimized for your use and benefit;
- To operate, maintain and provide to you the features, and functionality of the Sites, Software and Service;
- For market research, project planning, troubleshooting problems, detecting and protecting against error, fraud, or other criminal activity; and
- To communicate with you to provide you services, contacts, materials and/or recommendations for your needs as identified by you through phone, email, or the Sites;
- To carry out our obligations arising from any contracts entered into between you and us, or the contracts between us and merchants using Squirrel to power their business;
- To comply with internal policies and procedures and other legal, accounting, or security requirements;
- To share your personal information with our employees, contractors, consultants and other third party service providers such as web hosting providers, advertising agencies, payment processors or customer service agencies (“Third Party Processors”) who require this information to assist us with establishing, maintaining and managing our relationship with you and optimizing and providing the Sites, Software or Service for your use and benefit. Please note that we may change or add Third Party Processors at any time, in our sole discretion, either in Canada or elsewhere. We encourage you to reference this Policy from time-to-time, to obtain updated information. Given the nature of cloud services, personal information may be stored outside Canada, anywhere in the world, and may be accessible to foreign courts, law enforcement and national security authorities in the jurisdiction(s) where it is transferred or stored.
We will only process your personal information for the Purposes for which we intend to process such information. Otherwise, we will not process your personal information without your consent.
- Disclosure of Your Personal Information
We may disclose your personal information for the Purposes as described in this Policy in the following ways:
- To our employees and contractors;
- To our business partners and merchants;
- To our service providers including online hosting providers, advertising agencies, payment processors and customer service agencies;
- To law enforcement, government or regulatory bodies, or other lawful authorities; and
- In the event of a direct or indirect reorganization process including, but not limited to, mergers, acquisitions, divestitures, bankruptcies, and sales of all or a part of our assets, we may disclose your personal information following completion of such transaction and/or during the assessment process pending transfer. If transferred in such a case, the purchaser will abide by the terms and conditions of this Policy.
Your personal information that we collect may be processed outside of Canada. As a result, your personal information may be accessible to law enforcement and regulatory authorities in accordance with other jurisdictions’ applicable laws.
- Legal Basis for Processing Your Personal Information
We will process your personal information only with your knowledge and consent, except where exempted, required or permitted by applicable laws. The form of consent may vary depending on the circumstances and the type of information being requested. Your consent may be express with clear options to say “yes” or “no”, such as by being asked to check a box to indicate your consent, or implied, such as when you provide us with your address through a form or email seeking information and we use those means to respond to your request. Your consent can also be provided by your authorized representative. Taking into account the sensitivity of your personal information, purposes of collection, and your reasonable expectations, we will obtain the form of consent that is appropriate to the personal information being processed. By using our Sites, Software or Service, or otherwise by choosing to provide us with your personal information, you acknowledge and consent to the processing of your personal information in accordance with this Policy and as may be further identified when the personal information is collected. When we process your personal information for a new purpose, we will document that new purpose and ask for your consent again.
If you do not consent to the processing of your personal information in accordance with this Policy, please do not access or continue to use any of the Sites, Software or Service or otherwise provide any personal information to us.
You may refuse to provide consent or may notify us at any time that you wish to withdraw or change your consent to the processing of your personal information without penalty, subject to legal or contractual restrictions and reasonable notice by (i) changing your privacy preferences through the Sites or Software, (ii) deleting your account with the Sites or Software and stopping use of the Sites or Software, or (iii) opting out of the use of your personal information such as unsubscribing to any functionality, notification, newsletter or mailing list subscription as applicable that we provide through the Sites or Software. However, if you withdraw or change your consent, we may not be able to provide you with the Service through the Sites or Software.
Other Legal Bases
Aside from consent, we may also process your personal information under other legal bases, as permitted by the applicable laws.
- Do Not Track Disclosure
The “Do Not Track” (“DNT”) privacy preference is an option that may be made in some web browsers allowing you to opt-out of tracking by websites and online services. At this time, global standard DNT technology is not yet finalized and not all browsers support DNT. We therefore do not recognize DNT signals and do not respond to them.
- Links to Third Party Pages/External Pages
To the extent that our Sites contains links to other apps or sites, the owners of those sites are responsible for the privacy practices or content of those other sites. We do not endorse and are not responsible in any way for the privacy practices on thirdparty websites.
- Security of Personal Information
The security of your personal information is important to us. We protect personal information using physical, technological and organizational safeguards. We regularly review our practices to ensure they align with reasonable industry practices appropriate to the level of sensitivity to safeguard personal information against loss or theft, unauthorized access, alteration or disclosure.
However, no method of transmission over the Internet, or method of electronic storage, is completely secure; as such, despite our safeguards and protocols, we cannot fully guarantee the security of your personal information and you should always exercise caution when disclosing personal information over the Internet.
By using the Sites or providing personal information to us, you agree that we can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Sites. We may post a notice on our Sites if a security breach occurs. We may also send an email to you at the email address you have provided to us in these circumstances. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.
- Requests for Access to and Correction of Personal Information
Applicable privacy 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. You may request access to and review of your personal information in our possession. However, access may be declined where permitted or required by applicable law.
You may request that we change or delete your personal information in our possession. We reserve the right not to change any personal information if we do not agree that it is inaccurate or outdated, but will append any alternative text the individual concerned believes appropriate.
If access cannot be provided, we will notify the individual making the request within 30 days, in writing, of the reasons for the refusal.
Please see Section 12 for further information about rights that may be applicable to you.
- CASL Policy
We are committed to compliance with Canada’s Anti-Spam Legislation (“CASL”). Any electronic communication we send to outside parties is protected by a range of business procedures, processes and policies to ensure that such communication is done in compliance with CASL. In our electronic communications with outside parties, we comply with the rules established by CASL and enforced by various Canadian authorities including the Canadian Radio-television and Telecommunications Commission. CASL regulates, and our policies generally apply to, each commercial electronic message (a “CEM”) that we send. A CEM is an electronic message sent to an electronic address that, among its purposes, encourages participation in a commercial activity.
In addition to adopting and updating this Policy, we undertake various transparency initiatives to ensure we comply with CASL, which include:
- Consent— we do not send you CEMs without your consent. This consent typically must be “express” (expressly acknowledged by you), but in certain circumstances can be “implied” or specifically exempt from consent requirements. We modified or adopted our sign-up, registration and consent forms in order to ensure that your consent is meaningful (i.e. informed and freely given) as per CASL. When we collect your electronic contact information, you will know the exact purposes behind the collection.
- Content— we adopted processes to ensure that our CEMs contain the following requirements prescribed under CASL, which will usually be in the footer of the CEM. We will:
- Identify ourselves as the party sending the CEM, and whether we are sending the message on our own behalf or on behalf of someone else;
- Provide you with our contact information; and
- Set out a clear, working unsubscribe mechanism or preference centre that is easy to use, automatic, and at no cost to you (other than your own cost of connecting to the Internet).
- Clarity— we ensured that each aspect of a CEM, including its header, content, or any links or URLs in the CEM) conveys the appropriate information, whether viewed individually or taken as a whole, so that you always know what you are clicking on.
If you receive a CEM from us but believe that you should not have or no longer wish to receive CEMs, we will aim to respect your preferences in a timely manner once you update them through our unsubscribe mechanism. CASL requires us to process unsubscribe requests within 10 business days. If you have any questions or concerns about our unsubscribe options, you may contact us at the address indicated in Section 13 below.
- Retention of Your Personal Information
We generally keep personal information for only as long as it is needed to accomplish the purposes for which it was collected, or as needed for authorized or legitimate purposes. More specifically, we retain personal information as long as necessary for the fulfillment of the identified purposes for its collection or as otherwise necessary to comply with applicable laws or protect our interests. When personal information is no longer necessary or relevant for the identified purposes, or is required to be retained by applicable laws, we will take steps to have it deleted, destroyed, erased, aggregated or made anonymous. We use reasonable industry practices to ensure we have adequate controls, schedules and practices for information and records retention and destruction which apply to personal information.
- Updates or Changes to this Policy
This Policy was last updated on May 15, 2022. We will occasionally update this Policy and revise the “last updated” date at the top of this Policy and in this paragraph.
If we make any material changes we will either (a) notify you by email (sent to the email address listed in your account), or (b) provide a notice on the Sites or otherwise through the Service before the change becomes effective. Any change to this Policy will apply to existing information, as well as information collected onwards from the date that this Policy is posted or on the date as specified in the notification. We encourage you to periodically review this page for the latest information on our privacy practices to ensure you are aware of any changes. Your continued use of the Service signifies your acceptance of any changes to this Policy.
- California Privacy Rights
You may have certain other rights regarding your personal information under applicable law:
- Right to Know: You may request information about the categories and specific pieces of personal information we have collected about you, as well as the categories of sources from which such information is collected, the purpose for collecting such information, and the sale or disclosure for business purposes of your personal information to third parties, and the categoires of third parties with whom this information was shared;
- Right to Delete: You may have a right to request that we delete personal information under certain circumstances.
- Right to Opt Out of the Sale: You have the right to opt out of the sale of your personal information to third parties. We do not sell your personal information at this time, we do not share your personal information with third parties for their direct marketing purposes, and we do not sell the personal information of children under 13 years old; and
- Right Not to Be Discriminated Against: You have the right to not be discriminated against for exercising any of the rights mentioned above. This includes not being discriminated against in connection with financial incentives, which we may offer from time to time.
You can exercise your rights by contacting us using the details set out in Section 13 below. Whenever feasible for verification, we will match the identifying information provided by you to the personal information already maintained by us. If, however, we cannot verify your identity from the information already maintained by us, we may request additional information. You may designate an authorized agent to make a request on your behalf. Such authorized agent must have permission to submit requests on your behalf. We may deny a request from an agent that does not submit proof that they have been authorized by you to act on your behalf.
Shine the Light Disclosure
California Civil Code Section 1798.83 (California’s “Shine the Light” law) allows California residents to request certain information regarding disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please put “Shine the Light” in your communication to us through the contact methods provided below.
- Contact Information for Privacy Officer
You can direct any questions or concerns regarding our compliance with this Policy and our processing of your personal information to our Privacy Officer by emailing firstname.lastname@example.org.
We strive to offer an accessible and simple complaint procedure. We will promptly investigate all complaints received, and if a complaint is justified, we will take the necessary steps to resolve the issue in question.