Last updated: March 2021.
OUR APPROACH TO PRIVACY
The protection of your personal information is of the utmost importance to Babbl Communications Ltd., its subsidiaries, divisions and affiliates (“Babbl”, “we”, “us” or “our”, as appropriate).
In some instances, our products and services or those offered by a third-party service provider to our customers or users may have their own specific privacy policies. Customers or users may be asked to consent to the additional privacy policies before using these products or services.
WE RESPECT YOUR PRIVACY
Your privacy is important to us. We are committed to protecting and ensuring the confidentiality of any personal information you provide to us.
- How we obtain consent to collect, use and disclose personal information;
- What types of personal information we collect;
- How we may use that information;
- How we may disclose that information;
- How we protect that information;
- How you may access or correct any of your personal information held by us; and
- How you may contact us should you have questions or concerns about your privacy.
Your consent to the collection, use or disclosure of personal information may be implied or express, through written, oral, electronic or any other method. When it is reasonable in the circumstances, we may imply consent from your actions. We may ask for your express consent when or collection, use or disclosure of personal information is more sensitive or not necessarily expected.
For example, when you provide us with your address, it is implied that it is used for billing purposes and service provisioning. However, if we are dealing with more sensitive information, such a performing a credit check, we well seek your express consent. We will also obtain your express consent for marketing purposes.
WITHDRAWING YOUR CONSENT
The choice to provide Babbl with you consent is always yours, however your decision to withhold such consent may limit our ability to provide you with certain products, services or offers.
You may withdraw your consent to the collection, use, and disclosure of your personal information at any time. Upon receiving your request, we will undertake to delete any of your personal information held by Babbl within a reasonable time, subject to any personal information that may need to be retained for purposes required or permitted by applicable law.
You may also request that we stop sending you commercial electronic messages (CEMs). Upon receiving your request, we will remove your electronic address from our mailing list within ten (10) business days.
Please direct any of the above requests to our Privacy Officer at firstname.lastname@example.org. In addition, we provide opt-out or withdrawal instructions in our CEMs to allow you to remove your name from future mailings.
COLLECTION OF YOUR PERSONAL INFORMATION
The personal information we collect and the method of collection depends on how you interact with us, and the products and services you use or to which you subscribe. We collect only the personal information that is strictly necessary for the Purposes described below (in the section entitled “Use of Your Personal Information”).
We may collect personal information in the following ways:
- when you provide your personal information during the inquiry, activation, purchase or subscription process for a product or service;
- when we provide services to our customers, including technical or customer support;
Types of personal information collected may include, but are not limited to,:
- Identification Information.
As part of our Services, we may ask you to provide us with certain personal information to allow us to identify you and communicate with you. Such information may include your name, mailing address, e-mail address and phone number.
- Relationship Information
We may collect information regarding your inquiries, purchases, regional location and other transactions, to allow us to offer you products and services that may interest you.
- Product or Inquiry Information
We use inquiry forms (e.g., on our website) to allow you to request information, including product, service or pricing information. Any personal information collected in these forms is used to fulfill your request or to better understand your request. We do not collect sensitive personal information such as social insurance numbers or financial information in these inquiry forms, other than we may need to collect credit card information to process payment obligations on your account.
- Anonymous Information
By using our Services, you agree to the collection of certain information that we use to improve the functionality of our Services. Such information may include website visitor demographics (e.g., language), what web pages our visitors are browsing to, the amount of time spent on each page, the device type used to visit the website, and other technically relevant information. Once collected, this information is not tied to you personal, and is used in aggregate with the information of other users so that we may better understand our customers and improve our Services.
- Information Collected Through Our Website
- IP address;
- Device type;
- Operating system;
- Browser language;
- Our web pages that you visited, time on the website, and total number of pages viewed; and
- Network service provider.
You may use browser, app or device controls to prevent certain types of automotive information collection. However, if you choose not to provide or allow information that is necessary for certain Services or features, those Services or features may not be available or function correctly. For instance, you may manage the information we collect through our website by adjusting the cookie and privacy settings in your web browser or on your mobile device, but this may limit your online experience and available functionality on the website.
We may also obtain data and information about you from third parties, including, but not limited to:
- Credit information from credit reporting agencies.
USE OF YOUR PERSONAL INFORMATION
We collect your information for various reasons in order to provide you with our products and services and to improve those products and services to better serve you as a customer. Specifically, we may use your information for the following purposes (the “Purposes”):
- to provide you with the products or services you have purchased from us or for which you have subscribed, and to bill you and collect payment for those products or services.
- to understand your needs and offer you products or services that may be of interest to you.
- to perform customer support.
- to manage customer relationships and communicate with you, including responding to your inquiries and information requests.
- administer and validate warranties.
- to monitor, customize, and improve our communications with you.
- to manage invoicing, accounting, and information security services related to our transactions with you.
- to provide geo-location services that will send you offers and promotions from carefully chosen third parties based on your current and historical personal location information.
- to operate our websites, including online registration processes (e.g., for webinars and other online information sessions).
- to evaluate and/or improve the quality, performance, safety and security of our products and services.
- to help us develop new products, services and features to meet your needs as a customer.
- to notify you of recalls or safety issues.
- to perform troubleshooting.
- to confirm or authenticate your identity and ensure your information is correct and up-to-date.
- to detect, prevent, investigate or otherwise address fraud, unauthorized or illegal activity, security, or technical issues.
- to perform analytics, administer surveys, or request feedback to improve and manage our relationship with you.
- to ensure the Babbl networks are functioning and to protect the integrity of our networks.
- to protect against harm to the rights, property, or safety of Babbl, our customers, our employees, or the public, as required or permitted by law.
- to evaluate any application by you for employment with Babbl.
- to comply with any “Do Not Email” or other non-solicitation requests.
- to comply with any contractual requirements under contracts entered into with you.
- to ensure compliance with our Terms of Service and Acceptable Use Policy.
- to comply with legal or regulatory requirements, including as part of an investigation of a security incident or cooperation with governmental authorities pursuant to a legal matter.
- to perform marketing, including interest-based marketing and advertising.
- browsing and system information may be used to personalize and optimize your website experience.
From time-to-time, information may also be collected for other purposes, or as permitted or required by law. We will always identify any additional purpose prior to, or at the time of, collection.
We will not use any information provided by you through the Contact Us forms of our websites or via telephone for unsolicited marketing purposes.
We may anonymize your information in a way that it can no longer reasonably be associated with you. We may use anonymized information or share it with third parties for any legitimate business purpose, including, but not limited to,: helping us understand trends and customer needs; assisting in product selection, ordering, and sizing; introducing new product and service offerings; and optimizing our websites’ rankings in third party search engines.
DISCLOSURE OF YOUR PERSONAL INFORMATION
Third-Party Service Providers. We may share, without your consent, your personal information with service providers that we use to facilitate or outsource one or more aspects of the operation of our Services or our business (e.g., hosting our website and online services, backup/archival services, tracking website usage, marketing our Services, and communicating with our customers), provided that any use of the information is in accordance with the Purposes, and such information is necessary for the performance of their functions. We require all our service providers to sign agreements in which they promise to protect personal information using safeguards reasonably similar to ours. Further, these service providers are subject to confidentiality and security agreements with Babbl and other legal restrictions that prohibit their use or unauthorized access of any personal information we provide to them for any purpose other than to facilitate specific processing operations in accordance with the Purposes. Any disclosure of your personal information for purposes other than the Purposes will require your prior consent.
General. With regard to any disclosures of your personal information, we will ensure that (i) the use of your personal information is consistent with the Purposes, (ii) your personal information will not be disclosed to third parties without your prior consent (except if such disclosure is consistent with the Purposes or if provided for by applicable law), and (iii) reasonable measures have been or will be implemented to protect your personal information against any unauthorized access or use.
Aggregated Data. We compile aggregate usage statistics of our Services from data collected through or in connection with the Services (e.g., through website cookies). We may publish those statistics or share them with third parties, but they do not include personal information.
CONFIDENTIALITY & SECURITY MEASURES
We maintain security measures in accordance with industry standards to protect and ensure the confidentiality of your personal information. We employ reasonable physical, administrative, contractual, and technological safeguards to guard against loss, unauthorized access, misuse, or alteration of personal information under our control. Access to personal information is restricted to authorized personnel who require such information to properly perform their duties, and access is limited to only that information that is strictly necessary for the performance of those duties. Further, we insist that our service providers implement similar safeguards to protect the personal information of Babbl customers or users.
Due to the nature of the Internet, no systems are impenetrable, and the security measures undertaken by Babbl may not fully protect your personal information in all cases. Babbl cannot guarantee that there will not be a breach in the confidentiality of your personal information; you should thus exercise care in using our Services. If you believe that your personal information held by Babbl has been compromised, we urge you to notify us promptly.
In the event that a breach of confidentiality involving your personal information occurs or is suspected, such as unauthorized access, use, disclosure, loss of personal information or any other breach of the security of such personal information, Babbl will take reasonable steps to reduce the risk of harm and to prevent similar breaches from occurring in the future. Babbl will notify you of any such breach of confidentiality that poses a real risk of significant harm to you.
- SSL Protection. Some password-protected areas of our Services require a secure connection with your computer. We use an encryption technology called Secure Socket Layers (SSL). A secure connection is maintained until you leave the secure area of the website. Babbl cannot guarantee the safety of transmitting personal information over the Internet.
- Password Protection. You are responsible for maintaining the confidentiality of your passwords. We have the right to assume that anyone accessing one of our Services using a password assigned to you has the right to do so. You will be solely responsible for the activities of anyone accessing our Services using a password assigned to you. You must promptly change your passwords if you see a risk of your password being compromised.
RETENTION AND DESTRUCTION OF YOUR PERSONAL INFORMATION
Your personal information is kept with our cloud storage/hosting provider, at a facility located in BC. As mentioned above (in the section entitled “Disclosure of Your Personal Information”), in some cases, personal information that we manage may be disclosed, processed, or stored in other Canadian provinces or territories, or abroad.
Your personal information will be retained for only as long as is necessary to fulfill the Purposes described herein or as otherwise authorized by you, or as is otherwise necessary to protect our interests or comply with applicable law. When your personal information is no longer necessary for the Purposes, we will delete, destroy, aggregate, or otherwise anonymize your personal information, subject to any retention period provided by applicable law.
As described above, any anonymization of your personal information will be done in such a way that it can no longer reasonably be associated with you. We may use anonymized information or share it with third parties for any legitimate business purpose, including, but not limited to,: helping us understand trends and customer needs; assisting in product selection, ordering, and sizing; and introducing new product and service offerings.
RIGHT TO ACCESS AND CORRECT YOUR PERSONAL INFORMATION
To protect your privacy, you may be required to provide authenticating information prior to gaining access or making changes to you personal information. We undertake to respond to all requests to review or request changes to personal information within 30 days. In some cases, we may not be able to allow you to access certain personal information in certain circumstances (e.g., if the file contains personal information of other persons, or where required by law). In such event, we will provide you with a reasonable explanation of why it is not possible to grant access to your personal information.
To the extent permitted by law, Babbl assumes no responsibility for verifying the ongoing accuracy of personal information.
We are committed to providing transparency with respect to our practices in complying with Canada’s anti-spam laws (“CASL”). From time to time, we may send commercial electronic messages (“CEMs”), including (i) to our current or potential clients (whether individuals or businesses) (e.g., for prospecting purposes or to respond to an inquiry or request for information); and (ii) to our current or potential service providers or business partners. We may also delegate the distribution of Babbl CEMs to a third party service provider, in which case the CEM will be identified as being sent on behalf of Babbl.
We only send CEMs to those recipients that have either provided their express consent to receive CEMs from Babbl, or where permitted by law, including without limitation (i) due to an existing business relationship between Babbl and you; (ii) within a certain period after the end of any such business relationship; (iii) within a certain period after an inquiry or request for information by you; (iv) in the form of a single CEM, following a referral by a current Babbl client, service provider, business partner, or employee who also has a personal, family, or business relationship with you; and (v) in the event that you conspicuously published your email address or voluntarily disclosed it to Babbl or one of our employees or agents (without an indication that you do not wish to receive unsolicited CEMs).
If you wish to stop receiving CEMs from us, you may do so by using the unsubscribe mechanism found at the bottom of any Babbl CEM, or by contacting us at email@example.com with “UNSUBSCRIBE” in the subject header. We will remove your e-mail address from our mailing list within ten (10) business days.
We do not knowingly collect personal information from or market to children under the age of 13 years old. If a child under the age of 13 has provided personal information to Babbl through our website or other Services, a parent or guardian may contact our Privacy Officer to request that the information be deleted from our records. Following receipt of such a request, we will make reasonable efforts to delete the child’s information from our records.
- E-mail: firstname.lastname@example.org; or
If you are not satisfied with Babbl’s response, you may contact the Office of the Privacy Commissioner of Canada for further guidance at:
- Website: priv.gc.ca/en
- Toll-free: 1-800-282-1376
- Phone: (819) 994-5444
- Fax: (819) 994-5424
Office of the Privacy Commissioner of Canada
30 Victoria Street