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Software Privacy Policy

1. Privacy

Municipal Media Inc. (“us,” “we,” “our”, or “Municipal Media”) respects the privacy rights of our customers, visitors, and other users of our “Recycle Coach” online solid waste and recycling information services (collectively, “Services”) provided through our website, web application, and any application software for any platform (iPhone, Android, etc.) that you may download, access (including via web browser), or otherwise use from time to time (collectively, the “Software”). We created this Software privacy policy (“Privacy Policy”) to give you confidence as to the security of your information as you use the Software, and to demonstrate our commitment to the protection of any personal information we hold.

Municipal Media is responsible for the personal information we collect and hold. To ensure our ongoing accountability to you, we have developed this Privacy Policy and trained our employees about our policies and practices.

This Privacy Policy is only applicable to individual users of the Software and/or the Services, excluding businesses and other organizations. The website portion of our Software may contain links to other websites and/or may be integrated with other software created by third parties. Those third-party sites or software components are not governed by this Privacy Policy, as they are not controlled by us. Similarly, our Software and/or Services may be embedded in other third-party websites that are not administered by us, and those sites are not governed by this Privacy Policy. You should carefully review the policies of all third-party websites and applications. Your use of the Software is governed by this Privacy Policy and the Terms of Use (as described below).

2. Software and Technical Data Collected

We automatically track and collect the following categories of information when you use our Software: (1) IP (which stands for Internet Protocol) addresses; (2) domain servers; (3) types of computers/devices accessing the Software (including type of computer or phone, and operating system version); (4) types of web browsers used to access the Software; (5) referring source which may have sent you to the Software; and (6) other information associated with the interaction between your browser and the Software (collectively, “Software Data”). Other Software Data that we may automatically collect from time to time may include information concerning the full Uniform Resource Locators (URLs), clickstream to, through and from our Software (including date and time), pages you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

3. Personal Information Collected

We provide our Services through our Software. In order for you to access certain features of the Software, we require you to provide us with certain personal information that may identify you, or from which your identity could be deduced (collectively, “Personal Information”). Personal Information may include: (1) Contact Data (such as your name, e-mail address, and phone number); (2) Demographic Data (such as your gender and your age); and (3) Location Data (such as your address or zip/postal code). If you communicate with us by, for example, e-mail or letter, any information provided in such communication may be collected as Personal Information.

You may choose not to provide us with any Personal Information. In such an event, you can still access and use certain portions of the Software; however, you will not be able to access and use those portions of the Software that require your Personal Information, and the Services may be less accurate and useful to you.

If you access any Services requiring a username and password, you are solely responsible for keeping such items strictly confidential.

4. How We Collect Software Data and Personal Information

We use different methods to collect your information (including Software Data and Personal Information – collectively, the“information”), including through:

·     Direct interactions with you when you provide it to us, for example, by filling in forms or surveys, completing games or quizzes, registering an account, or corresponding with us by phone, email, or otherwise.

·     User contributions, namely when you provide information for us to publish or display on public areas or transmit to other Software users or third parties.

·     Automated technologies or interactions, as you navigate through, use, and interact with our Services. Information collected automatically may include usage details, IP addresses, and information collected through cookies and other tracking technologies.

·     Third parties or publicly available sources, for example, our municipal and other government partners and our waste and recycling collection partners.

The information we collect directly from you on or through our Services may include:

·     Information that you provide by filling in forms or inputs on our Services. This includes information provided at the time of registering an account with our Services, using our Services, and requesting further Services or assistance. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Services.

·     Records and copies of your correspondence (including email addresses), if you contact us.

·     Your responses to surveys and queries that we might ask you to complete for research purposes, whether inside or outside of the Software.

5. Cookies

“Cookies” are computer files that are placed on your computer by a website. In these files, various pieces of information can be stored, from user identification and preferences to activities conducted while browsing the website. You may block cookies or delete cookies from your computer if you wish but must do so at your own cost and responsibility. If you do block or disable cookies, and you are accessing the Software through a website, then you may not have access to the entire set of features of our Software.

Generally, we use “cookies” to customize your experience on our website and to store your password so you do not have to re-enter it each time you visit the website.

We may also use these technologies to collect information about your online activities over time (behavioural tracking). We may link the information stored in these cookies directly to any of your Personal Information that you expressly or automatically submit while using the Software. The information we collect automatically is statistical data and does not include Personal Information. It helps us to improve our Services, including by enabling us to:

·     Estimate our audience size and usage patterns.

·     Store information about your preferences, allowing us to customize our Services according to your individual interests.

·     Speed up your searches. 

·     Recognize you when you return to our Services.

6. Storage of Information

Except as otherwise permitted or required by applicable law or regulation, we will only retain your Personal Information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize your Personal Information so that it can no longer be associated with you (and no longer constitutes Personal Information). We reserve the right to use such anonymous and de-identified information and data, including all Software Data, at any time and for any legitimate business purpose without further notice to you or your consent.

7. Personal Information and Electronic Documents Act and Related Acts

From January 1, 2004, all businesses engaged in commercial activities must comply with the Personal Information Protection and Electronic Documents Act (“PIPEDA”) and the Canadian Standards Association Model Code for the Protection of Personal Information that it incorporates, in addition to all applicable provincial privacy laws and codes. PIPEDA gives you rights concerning the privacy of your personal information. If you are located outside of Canada, you may have local laws which protect the collection and use of your personal information.

8. Municipal Media's Use of Your Information

We may use information that we collect about you or that you provide to us, including any Personal Information:

·     to present the Services and their contents to you, including to provide you with information or services that you may request from us;

·     to send you information about Municipal Media,Recycle Coach, or our products or Services more generally; 

·     to fulfill the purposes for which you provided the information to us or that were described when it was collected, or for any other purpose for which you provided it;

·     to allow you to participate in interactive features or similar functions on our Services;

·     to contact you when required, including to advise you about changes to your garbage and recycling information or changes to the Services we offer;

·      to customize your experience on the Software;

·      in any other way we may describe when you provide the information; and for any other purpose with your consent.

9. Information Sharing and Disclosure

In addition to how we use your information (described above), we may share certain categories of information we collect from you in the ways described in this Privacy Policy.

We may share any of your information with our subsidiaries and affiliates.

We may share your information, including Demographic Data and Location Data, with other third parties but only on an aggregate and confidential (i.e., non-personally-identifiable) basis.

We may occasionally provide the Services in partnership with your local or other applicable government. We may also facilitate contact between you and your local or other applicable governmental entities to resolve waste and recycling related issues. By using the Software and Services and providing us with Personal Information, you consent to our sharing of such information with your local government, as well as any information that may be relevant to a request for services or assistance that you make. We will not share any more information with any level of government than is necessary to achieve the necessary or requested task.

We also share Personal Information with our business partners who assist us by performing core services related to our operation of the Software and Services. Those business partners shall be bound to uphold the same standards of security and confidentiality that we have promised to you in this Privacy Policy, and they will only use your Personal Information to carryout their specific business obligations to Municipal Media and to provide your requested Services. We may also transfer information about you to third parties in connection with a merger, sale or acquisition by or of Municipal Media.

We may share your Personal Information and Software Data with third-party contractors and service providers we use to facilitate the seamless integration of different software components. For example, we may share your login information with such third-party software providers to avoid the need for you to login to multiple accounts in the course of using a single website or application. In some cases, third-party software providers may have provided us with Personal Information that you shared with them, also for the purpose of facilitating the seamless integration of different software components.

We may otherwise use your information to fulfill the purpose for which you provide it. For example, if you give us an email address to use the referral feature of our Software, we will transmit the contents of that email and your email address to the recipients. We will otherwise use such information for any other purpose disclosed from us from time to time.

In addition to the above, we may disclose your information to comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law, to enforce or apply our Terms of Use, or if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Municipal Media, our partners, or others.

Except as described herein, we will not process, store, or transfer your Personal Information in and to a foreign country. For Canada-based and international users, such Personal Information will always be stored and processed in Canada. For U.S.-based users, such Personal Information will always be stored and processed in the United States of America.

10. Controlling and Correcting Your Personal Information

Since we use your Personal Information to provide Services to you, it is important that your Personal Information be accurate and up-to-date. If any of your Personal Information changes, please advise us so that we can make any necessary changes (you can either write to us directly or, if you are a registered user of our Software, you can modify some of your Personal Information you have included in your profile).

Upon your written request, we will use commercially reasonable efforts to delete your account and the Personal Information in your profile; however, it may not be possible to remove your account without some residual information being retained by us. Registered users who wish to close their account should contact support@recyclecoach.com.

If we hold Personal Information about you and you can establish that it is not accurate, complete, and up-to-date, we will take reasonable steps to correct it.

Where you have provided your consent to the collection, use, and transfer of your personal information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us at support@recyclecoach.com. Please note that if you withdraw your consent we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision.

11. Access to Your Personal Information

You may ask for access to any Personal Information we hold about you. Summary information is available on request. More detailed requests that require archive or other retrieval costs may be subject to our normal professional and disbursement fees.

Your rights to access your Personal Information are not absolute. We may deny access when:

·     Denial of access is required or authorized bylaw; 

·     Information relates to existing or anticipated legal proceedings against you;

·     When granting you access would have an unreasonable impact on other people’s privacy;

·     When to do so would prejudice negotiations with you;

·     To protect our rights and property; or 

·     Where the request is frivolous or vexatious.

If we deny your request for access to, or refuse a request to correct your Personal Information, we will explain why.

12. Security

The security of your Personal Information is important to us. We take reasonable precautions to ensure that your Personal Information is kept safe from loss, unauthorized access, modification, or disclosure. Among the steps taken to protect your Personal Information are:

·     premises security;

·     restricted file access to personal information;

·     deploying technological safeguards like encryption and security software and firewalls to prevent hacking or unauthorized computer access; and 

·     internal password and security policies.

“Phishing” is a fraudulent practice designed to steal your Personal Information. If you receive an e-mail that looks like it is from Municipal Media asking you for your Personal Information, do not respond. We will never request your password, user name, credit card information, or otherPersonal Information through e-mail.

A website or other application cannot be completely absolutely protected against intentional or malicious intrusion attempts. Further, we do not control the devices or computers or the internet over which you may choose to send Personal Information and cannot, therefore, prevent such interceptions of compromises to your Personal Information while in transit to us. If we learn that your Personal Information has been disclosed in a manner that is not in accordance with this Privacy Policy, we will use reasonable efforts to advise you of the disclosure as soon as reasonably possible.

The safety and security of your information also depend on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Services or Software, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

13. Lost or Stolen Information

You must promptly notify us if your Contact Data is lost, stolen, or used without your permission. In such an event, we will remove that Contact Data from your account and update our records accordingly.

14. Integration with Other Software

Our Software may contain links to third-party websites and/or is integrated with the software of third-party providers with whom which Municipal Media has no affiliation. Except as disclosed in this Privacy Policy, we do not share your Personal Information with those service providers and we are not responsible for their privacy practices. Some websites and software maybe similar to our Software. Please be cautious that you may be using a third party’s software and that this Privacy Policy only covers our Software. Should you decide to visit one of these third-party websites or use their software, we recommend that you read that provider’s privacy policy.

15. Updates and Changes to Privacy Policy

Since we regularly review all of our policies and procedures, we may change or update our Privacy Policy from time to time. All changes will be posted on our website and will immediately become effective without further notice to any party. In all cases, use of the information we collect is subject to the Privacy Policy in effect at the time such information is collected.

16. E-mail

You should be aware that e-mail is not an entirely secure medium. You should be aware of this when using e-mail to send or receive personal or confidential information

17. Limitation of Liability

We make no guarantee as to the security, integrity, or confidentiality of any information transmitted to or from our Software, or stored within our Software.  Beyond our reasonable care to safeguard your information while in transit, Municipal Media does not guarantee the absolute security of electronic communications or transmissions since any transmission made over the internet by anyone individual runs the risk of interception.

You assume the sole risk of transmitting your PersonalInformation as it relates to the use of our Software, and for any data corruptions, intentional interceptions, intrusions or unauthorized access toPersonal Information, or of any delays, interruptions to or failures preventing the use of our Software.  In no event shall we be liable for any direct, indirect, special, consequential or monetary damages, including fees and penalties in connection with your use of the Services provided by our Software or connectivity to or from this site to any other site.

If your non-identifiable data is used for research purposes, then the limitation of liability provision set forth above is waived with respect to any harms suffered or liabilities incurred as a result of any research activities.

18. Contacts

If you have any questions concerning our Privacy Policy, or wish to access your personal information, please write to our Privacy Contact at:

Municipal Media Inc.
50 Carroll St., Ste.111
Toronto, ON M4M 3G3 Canada

Tel: 416.423.3203
Email: support@recyclecoach.com

BY USING THE SOFTWARE AND/OR THE SERVICES, YOU ACCEPT THE TERMS OF THIS PRIVACY POLICY IN ITS ENTIRETY WITHOUT ANY MODIFICATION.