Onlia Sense Privacy Notice
Onlia Services Inc. (“OSI”) is committed to protecting your privacy. In this Onlia Sense Privacy Notice (the ‘Notice’), ‘we’, ‘our’, or ‘us’, refers to OSI and its subsidiaries and affiliates. The Notice (i) describes the personal identifiable information (the ‘Personal Information’) that we may collect through our Onlia Sense mobile application (the ‘App’) and/or our website: www.onliasense.ca (the ‘Sense Website’), which is owned and operated by Onlia Holding Inc., (ii) explains the purpose of collecting and the use of such Personal Information, and (iii) explains how and when we may share it.
We are responsible for all Personal Information under our control, whether supplied to us directly by you or by a third party, or that we have provided to a third party for processing. We have established policies and procedures to comply with this Privacy Notice and have a Privacy Officer who is responsible for ensuring we comply with privacy legislation. If you need to contact our Privacy Officer regarding your specific privacy questions or concerns please see the contact information at the end of the Notice.
The collection of Personal Information by OSI is limited to that which is needed for the purposes identified by us. Information is collected by fair and lawful means only.
OSI collects your Personal Information directly from you for the following purposes:
- to confirm your identity
- to register you as a user of our services and make changes to your user profile information and associate you with a reward program (the “Reward Program”) for the purpose of rewarding you with Badges or Perks
- to market or remarket a product or service, either directly, through loyalty partners, affiliates, third party service providers, or advertisers
- to understand your product and service needs, to build knowledge and conduct research around user’s driving behaviour and encourage better driving behaviour
- to communicate with you, including responding to your questions or inquiries
- to allow us to operate the Sense Website and the App in accordance with our Conditions of Use available here
- to allow us to assess, investigate, defend, and settle claims against us
- to manage and assess our risks, operations and relationship with you
- to ensure compliance with legal, regulatory, governmental and contractual requirements
- to detect and prevent fraud
- to analyze business results, compile statistics, perform administrative tasks such as accounting and information system activities and conduct marketing and underwriting research and modeling
- to train employees and monitor for quality assurance
- to act as required or as authorized by law
We may also use your Personal Information for other purposes with your consent or as permitted or required by law. If we require your Personal Information for any purpose other than as identified above, OSI will seek your consent prior to using it.
Consent to collection of personal information
Subject to certain legal and contractual restrictions and reasonable notice, you may refuse or withdraw consent to the collection, use or disclosure of Personal Information at any time by contacting our Privacy Officer. In addition, you may also opt out of certain communications we may send you regarding other products and services. However, you should be aware that withdrawing your consent may affect our ability to provide you with our services.
Collection of personal information
The Personal Information that we collect comes directly from you through the Sense Website, or through the use of the App. We obtain your consent electronically for the collection, use and disclosure of your Personal Information in accordance with this Privacy Notice, and, depending on the circumstances, for other purposes identified prior to the collection of your Personal Information.
Unless required by law, OSI will not collect, use or disclose Personal Information without obtaining your consent first. Your consent can be “implied” or “express”. Implied consent refers to conduct which demonstrates voluntary provision of Personal Information, for example, when you provide Personal Information for the purpose of registering in the Reward Program. Express consent refers to circumstances where you are provided with explicit disclosure regarding the nature of the collection, use, and disclosure of your Personal Information. If OSI ever wishes to collect, use, or disclose your Personal Information for purposes other than those identified in our Privacy Notice, OSI will obtain your express consent.
The types of Personal Information that we may collect in order to fulfill the purposes identified above include your individual's name, telephone number, profile photo, e-mail and mailing address. If you download the App, we will collect information on your driving habits such as mobile device location (GPS), accelerometer, gyroscope (motion and fitness) data, time of day travelled, and events recorded by the App (collectively, the “Collected Data”) in order to be able to e.g. give you a score, safety information, or badges or rewards on the basis of your driving behaviour.
Cookies, automatic data collection, and related technologies
If you choose to delete or disable web-based technologies that monitor your browsing behaviour or track your location, you may not be able to use the App and participate in the Reward Program. Please refer to the applicable Conditions of Use to learn more.
The Sense Website also contains links to other sites. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of any other site that collects personally identifiable information.
Limiting use, disclosure, and retention
Unless you consent, otherwise or it is required by law, Personal Information can only be used or disclosed by us for the purposes for which it was collected. We keep Personal information only as long as required to serve those purposes.
There are situations specific to our business where we will use, disclose and retain Personal Information as dictated by prudent business practices. Examples of these situations include:
- Storage of Information: transfer of Personal Information to cloud providers;
- Regulatory: compliance with legal, audit and other regulatory or governmental regulations.
OSI may internally share your Personal Information for the purposes identified in this Notice with its employees, affiliates or other related companies in- or outside of Canada. Only such companies with legitimate business reasons will have access to your Personal Information and must ensure that Personal Information in their possession is securely held.
We may disclose your Personal Information to third-party service providers, third-party loyalty partners, and third-party advertisers. Third parties are also subject to applicable privacy legislation. Only those companies or individuals who are authorized, based on their need to carry out work for the purposes identified herewith, can have Personal Information disclosed to them.
We may disclose only the following information, in an anonymized manner to third-party analytics service providers, third-party advertisers, and third-party loyalty partners:
- Age, sex, postal code
- Driving behaviour scores
- The Badge or Perk earned through the App; and
- Statistical and non-statistical Collected Data.
We may transfer any Personal Information that we have about you in connection with a merger or sale involving all or part of our business or as part of a corporate reorganization or stock sale or other change in corporate control.
We try to ensure that the Personal information that we collect is accurate, complete, and up-to-date as possible in order to properly satisfy the purposes for which it is to be used. If we are unable to verify your Personal Information or contact you, we may be limited in our ability to provide you with our services.
Protecting your Personal Information is very important to us, so we have taken the necessary organizational, technological and physical safeguards to protect it. When you submit sensitive information via the Sense Website or the App, your information is protected both online and offline.
Wherever we collect sensitive information, that information is encrypted and transmitted to us in a secure way. You can verify this by looking for a lock icon in the address bar and looking for "https" at the beginning of the address of the Web page.
While we use encryption to protect sensitive information transmitted online, we also protect your information offline. Only employees who need the information to perform a specific job (for example, customer service) are granted access to personally identifiable information. The computers/servers in which we store personally identifiable information are kept in a secure environment.
Any service providers we share your Personal Information with, are held to the same standard as us and are bound by our Privacy Notice and governing law.
Upon request, OSI will provide an explanation of its Notice with respect to the management of Personal Information. You can contact our Privacy Officer with any inquiries or complaints or if you require further information. Our goal is that your Personal Information shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.
If you would like to obtain a copy of the Personal Information held about you by us, or update, correct, or delete any information that you have provided to us through your use of the App or the Sense Website, or otherwise, or if you have any questions or suggestions for improving this Privacy Notice, please contact us. If you have questions about unsubscribing from email or other communications, you may do so using the email below in the Contact Us section. We may only deny access to your Personal Information when such denial is: (1) required or authorized by law; (2) when granting you access would have an unreasonable impact on other people’s privacy unless the requested information is severable from the personal information of other people; and (3) to protect our confidential commercial information. If we deny your request for access to, or refuse a request to correct information, we shall explain why.
Any individual may address a written challenge concerning our compliance with this Privacy Notice to our Privacy Officer at the contact information found at the end of this Notice.
OSI will investigate all written complaints. Should we find that a complaint has reasonable grounds, OSI will take all appropriate steps to correct the information and amend the Notice or practice as required and will notify the individual about the outcome.
Changing our privacy agreement
From time to time, we may update or make amendments to the Notice to comply with any changes in legislation or to take into consideration any other issues that may arise. Should we make any changes, we will post the revised Notice on the Sense Website and/or provide you with a notification through the App. We encourage you to check back often and keep yourself informed about our Notice. As we continue to serve you and where changes have been made to this Notice, our continued business relationship constitutes acceptance of those changes.
OSI welcomes any questions, comments or inquiries. Our preference is that you communicate with us through electronic means. You may contact our Privacy Officer regarding your specific privacy questions or concerns at:
Onlia Services Inc.
351 King St. E, Suite 801
Toronto, ON M5A 1L1
E-mail to opt-out of Commercial Electronic Messages: firstname.lastname@example.org
Effective date: December 10, 2018