Mylo Innovations Inc. and its affiliates and authorized third parties (collectively, “Mylo”, “we”, “our”, or “us”) respects your privacy and is committed to protecting your Personal Information (as defined below) in accordance with the British Columbia Personal Information Protection Act and other applicable provincial or federal legislation.
PERSONAL INFORMATION YOU PROVIDE AND HOW WE USE YOUR PERSONAL INFORMATION
In this Policy, “Personal Information” means information about an identifiable individual, including any Personal Information that is collected by us or supplied to us as a part of using our Online Accounts.
· Contact information: We collect your Personal Information when you contact us directly on any of our Online Accounts. This may include your first and last name, e-mail address, phone number, details of your pet (e.g. breed, age, gender, name) and other information that you choose to provide to us, including photographs.
· Use of your contact information: We use your contact information to contact and correspond with you directly about our relationship and your use of the Online Accounts and/or the Services. We may also use your contact information to provide you with information, Services and products that you have requested, and to provide you with information about any purchases made through the App.
· Account and profile information: We collect your Personal Information when you register for an account (“Account”) with us, and when you create or modify your Account. This includes information such as your first and last name, your e-mail address, phone number, username and password.
· Use of your Account and profile information: We use your Account and profile information to set up and administer your access to the App, to create and set up your Account, to provide you with the Services, to administer your use of the Online Accounts, and to provide you with information about any purchases made through the App. Your phone number is de-identified and is collected in order to send you a verification code.
· Use of your third party service provider information: We use your third party service provider information in the course of providing, administering and improving the Services.
· Payment information: We do not collect financial information directly from you through the App. We use third party payment processors, including Apple, to handle payments for us through the App. The third party payment processors will receive your billing information when you add it to your Account, or when you make a purchase through the App.
· Use of your payment information: We use payment information to facilitate payments for in-App purchases. As outlined above, we use a third party payment processor to handle payments made through the App.
· Social media information: When you visit one of our Online Accounts, we may collect personal information that you choose to submit to us such as your name, contact information, or any other information you choose to provide.
· Use of your social media information: We use your social media information for the purpose of responding to inquiries that you have made to us through social media and to facilitate any online forums in which you are able to contact Mylo or other Members.
· Ratings and reviews: We collect Personal Information that you may include in any feedback that you provide to us through our Online Accounts. This includes ratings and reviews given by Members of the Services, as well as feedback you provide to Mylo about the Online Accounts or Services. Ratings and reviews may be posted on third party platforms such as Google.
· Use of your ratings and reviews: We use rating and review information to improve the Online Accounts and Services, including to resolve technical issues on the Online Accounts. We may also use this information to investigate and address your concerns. In addition, we may use this information to suspend and deactivate your Account. We may post your first name, the first initial of your last name, and your city and province, along with your review on any Online Account. Reviews may be accessible to all visitors to the Online Accounts, so please ensure that you do not include any Personal Information in your reviews.
· Location and login information: When you are logged into the App, we collect Personal Information in relation to the GPS location of your phone as well as your most recent login information. GPS location services are only enabled when you are using the App.
· Use of your location and login information: We use GPS location information for the purpose of showing you where the closest dog-friendly locations are, as well as to see where mobile application rewards are collected. The collection of location and login information allows us to improve the App for Members based on the times and locations it is being used the most.
· Rewards information: We collect information about the App points you collect as well as any rewards redeemed in the App. We also collect information about instances where you are unable to collect points when you attempt to do so.
· Use of rewards information: We collect information related to your collection and redemption of rewards so we can offer the best rewards for Members based on their preferences.
· Other information: we may collect any of the information or content that you provide through our Online Accounts voluntarily.
2. COLLECTION OF PERSONAL INFORMATION
Mylo collects Personal Information when you interact with or use any of the Online Accounts. We also collect some Personal Information from you automatically, which is addressed in more detail below. In some cases, we may seek your consent for the use and disclosure of your Personal Information after it has been collected, but before it has been used or disclosed (e.g. where we want to use your Personal Information for a purpose not previously identified to you). We will not use or disclose your Personal Information for any new purpose without first identifying the new purpose and providing notice to or obtaining your consent (as applicable), unless permitted by law.
You can always choose not to provide us with certain of the Personal Information we request, however you may not be able to access or utilize all or part of the Online Accounts.
Mylo collects Personal Information in order to provide individuals with the Services, including but not limited to connecting Members with dog-friendly businesses by using intuitive technology that shows dog owners a map of dog-friendly locations, and collecting and redeeming rewards in the mobile application.
Personal Information Automatically Collected When Using Online Accounts and How We Use Your Personal Information
· Device, technical and usage information: Mylo collects device, technical and usage information about you via the Online Accounts, including your Internet Protocol (IP) address, web browser, device and mobile operating system, information about the sections of the Online Accounts that you visit, the date and time of your use of the Online Accounts and Services, your actions within the Online Accounts, the URLs of the website(s) you visited before and after using the Online Accounts and any content that you download from the Online Accounts.
This information is collected through “cookies”, pixel tags and web analytics. Cookies enable our Online Accounts to save and retrieve information that you enter (An example may include storing a customer’s password to their Account, to recognize a returning Member). Cookies may remain on your device after you leave the Online Accounts (until the cookie expires or is deleted by you). Pixel tags (also known as web beacons) are pieces of code embedded in the Online Accounts that collect information about your engagement on a web page. Third party web analytics tools, such as Google Analytics, Firebase, Drupal, App Store Analytics and Sensor Tower, track certain Online Account usage information in a way that does not personally identify you.
Use of your device, technical and usage information: We use device, technical and usage information to understand traffic and activity on the Online Accounts, to enable us to improve the Online Accounts and Services and to tailor our marketing. This information is used for aggregate reporting purposes.None of this data is used by Mylo or our Service Providers to identify you.
Before providing the Services, Mylo ensures that Members accept the Terms and Use governing our Online Accounts, which gives us consent for the collection, use and disclosure of Personal Information.
By accessing or using the Online Accounts, you acknowledge the notices in this Policy and you consent to our collection, use, disclosure and retention of your Personal Information in accordance with this Policy and as otherwise permitted by law. You may withdraw your consent at any time by giving us reasonable notice, but consent may not be withdrawn where doing so would frustrate performance of a legal obligation.
Consent to Receive Communications
Members consent to receive electronic communications from Mylo including but limited to, in the form of email sent to the email address provided, by push notification from the App, or by communications posted on any of our Online Accounts. Members acknowledge and agree that any electronic communication in the form of such email, push notification or posting satisfies any legal requirement that such communication be in writing.Upon registering an Account with Mylo, Members may receive email communications regarding the operations of our Online Accounts or the Services.Members cannot opt out of receiving these communications while they continue to use our Online Accounts or the Services.Members may also receive promotional emails while they use our Online Accounts or the Services.Members can opt out of these emails at any time by using the unsubscribe feature located in the footer of such email.
Withdrawal of Consent
Subject to certain legal and contractual restrictions and reasonable notice, consent to the collection, use or retention of Personal Information, or the sharing of Personal Information authorized third parties may at any time be withdrawn during the Services. Mylo will advise as to the implications of this withdrawal should it occur.
Withdrawal of consent to receive communications from Mylo may not be withdrawn during Services or the use of our Online Accounts, as detailed above.
4. DISCLOSURE OF PERSONAL INFORMATION
Except as described in this Policy or in other situations where Mylo has otherwise provided you with prior notice and, to the extent required by applicable law, obtained your consent, Mylo will not share your Personal Information with third parties.
Third Party Service Providers
Mylo’s Service Providers and other third party service providers will have access to Personal Information needed to perform their functions, but are only provided the limited amount of information required to perform their services. When Mylo uses Service Providers or other third party service providers, we require them to protect Personal Information in accordance with the law and with the same or more stringent security and privacy standards as Mylo. Any such disclosure of Personal Information by Mylo to a Service Provider or other third party service provider will be conditional upon the information being used solely for the purpose for which it has been disclosed.
Currently, other than our Service Providers, we use the following other third party service providers:
· Online Accounts design and operation: We use a third party application development company, Drupal, to design and maintain the online platform that we use for our Online Accounts.
· Website hosting: We use third party website hosting companies, Go Daddy and Blue Host, to host our website, https://www.pawswapapp.com/.
· Back-end services for the App: We use a third party backend-as-a-service company, Firebase, to develop our App.
· Electronic communications: We use third party email service providers, Mailchimp and Hubspot, to send electronic communications to Members.
· Hosting and content delivery network services: We use a third party host, Amazon AW, to host our Online Accounts and Services. Amazon AWS’s servers are resident in Canada.
· App access and download: We use the Apple App Store as the platform for Members to access and download the App.
· App payments: We use third party payment platforms, Stripe and Apple Pay, to process all payments made through an Online Account.
· Mobile App Store Marketing Intelligence: We use a third party marketing intelligence platform, Sensor Tower, to provide analytic information related to use of the App.
· Customer Relationship Management (“CRM”): We use a third party CRM service platform, HubSpot, to facilitate inbound marketing, sales and customer service.
· Phone Verification: We use a third party phone verification company, Twilio, to perform communication functions including phone number verification for Members.
In the event we go through a business transaction such as a merger, acquisition by another company, or a sale of all or a portion of our assets, your Personal Information may be among the assets transferred and any such acquirer of us or our assets may continue to collect, use and disclose your Personal Information as set forth in this Policy.
Where Required or Authorized by Law
Mylo may also disclose your Personal Information where authorized or required by law. For example, we may disclose your Personal Information to comply with requests from the Office of the Information and Privacy Commissioner, to comply with a subpoena, in response to a law enforcement body with the lawful authority to obtain the information, pursuant to an investigation into the breach of a law, or to our legal counsel.
5. SECURITY & PROTECTION OF PERSONAL INFORMATION
Mylo takes reasonable steps to protect Personal Information. We use security arrangements to protect against unauthorized access, collection, use, disclosure, and disposal, in a manner appropriate to the sensitivity of the information. We limit access to all Personal Information to Mylo personnel who have a need for such access in order to deliver the Services and to authorized third parties, including Service Providers.
Mylo will use care when destroying or disposing of Personal Information to prevent unauthorized access, use or disclosure of any Personal Information. Mylo’s employees and authorized third parties with access to Personal Information are required to respect the confidentiality of such information.
6. RETENTION OF PERSONAL INFORMATION
Personal information collected by us is maintained in accordance with applicable privacy legislation and our retention policies and practices. However, once you deactivate and remove your Account or stop using your Account for a period of twenty-four (24) months, we will delete any Personal Information on such Account immediately or after such period as may be required for retention by applicable laws.
7. CORRECTION AND ACCESS TO PERSONAL INFORMATION
Members can challenge the accuracy and completeness of their Personal Information in the possession and control of Mylo. In appropriate circumstances, Mylo will amend the Personal Information. Members can request access to their Personal Information and/or correction of that information by contacting Mylo in writing at the contact information noted below. In some cases, Mylo may also direct the individual to make the request to a third party directly, if applicable. In some cases, Mylo may not provide access to requested Personal Information in its possession or control, such as where the denial of access is authorized by law. There are also cases where Mylo may be legally required to refuse access to Personal Information.
8. QUESTIONS OR CONCERNS
Questions or concerns regarding this Policy, including the collection of Personal Information, can be directed to the Mylo Privacy Officer, who is responsible for ensuring Mylo’s compliance with this Policy. You can contact the Privacy Officer using any of the following methods:
Mailing Address: 404 – 999 Canada Place, Vancouver B.C. V6C 3A2
Telephone: 1 (877) 729-7927
Mylo takes any complaint about our privacy practices seriously, and will investigate all complaints. If Mylo finds a complaint justified, we will take the necessary steps to resolve it. The complainant will be informed of the outcome of the investigation regarding any complaint.
9. CHANGES TO THE POLICY
Mylo may update this Policy from time to time, in its discretion, and will make available any updated version on any of our Online Accounts, namely the App or our website.