Software Privacy Policy
1. Privacy
Municipal Media Inc. (“Municipal Media”, “Recycle Coach”, “us”, “we”, or “our”) respects the privacy rights of our customers, visitors, and other users of our “Recycle Coach” online waste and recycling information services (collectively, the “Services”) provided through our website, web application, and any application software for any platform (including iPhone and Android) that you may download, access, including via web browser, or otherwise use from time to time (collectively, the “Software”).
This Privacy Policy explains how we collect, use, disclose, store, and protect Personal Information and related technical information when you use the Software and Services.
Municipal Media is responsible for the personal information it collects through the Software and Services and for ensuring that such information is handled in accordance with applicable privacy laws.
In some cases, Municipal Media provides the Services on behalf of municipalities, local governments, and commercial delivery partners that support local waste and recycling programs. In those cases, such partners may be independently responsible for certain uses of Personal Information in connection with their own programs, communications, records, and legal obligations, and they are responsible for their own privacy notices and practices.
Municipal Media may also process Personal Information on behalf of those municipalities, local governments, and commercial delivery partners as a service provider or processor in order to deliver, operate, support, secure, and maintain the Services.
This Privacy Policy is only applicable to individual users of the Software and/or Services, and not to businesses and other organizations except as expressly described in relation to municipalities, local governments, and commercial delivery partners.
Similarly, our Software and/or Services may be embedded in third-party websites or platforms that are not administered by us. This Privacy Policy applies only to the Personal Information and related technical information that Municipal Media collects, uses, or discloses through the Software and Services under its control.
The website portion of our Software may contain links to other websites and/or may be integrated with software created by third parties. Those third-party sites, applications, or software components are not governed by this Privacy Policy where they are not controlled by us and you should carefully review the policies of all third-party websites and applications.
Your use of the Software is also subject to our Terms of Use.
2. Software and Technical Data Collected
When you use our Software or Services, we may automatically collect certain technical information about your device, browser, and interactions with the Software and Services (“Software Data”).
Software Data may include:
· Internet Protocol (“IP”) address.
· Domain server information.
· device type and version.
· Browser type and version.
· Referring source that may have directed you to the Software or Services.
· Information about how your browser or device interacts with the Software or Services; and usage information such as page visits, search activity, date and time of access, page response times, download errors, length of visits, page interaction information, and methods used to navigate away from a page.
We use Software Data to operate, maintain, secure, troubleshoot, and improve the Software and Services, to better understand how users interact with them, and to support performance, reliability, and user experience.
Software Data may also include information collected through cookies and similar technologies as described in Section 5 of this Privacy Policy.
Although Software Data is generally technical or aggregated in nature, in some cases it may be associated with Personal Information where necessary to operate, secure, support, or maintain the Software and Services in accordance with this Privacy Policy and applicable law.
3. Personal Information Collected
We provide our Services through our Software. In order to provide certain features of the Software and Services, we may collect limited Personal Information that identifies you or could reasonably be associated with you (“Personal Information”).
For residents using the Recycle Coach application, Personal Information collected is limited to what is necessary to provide core service features and related support. This may include:
· Required location information such as street address and, where applicable, postal code or ZIP/post code, in order to provide the correct municipal schedules, service information, and location based features;
· Optional contact information such as e-mail address and/or mobile phone number, where provided by you to receive service‑related notifications and reminders and updates by e-mail, SMS, or automated phone calls); and
· Optional identifying information, such as your name, where provided by you in connection with a service request or related communication so that Recycle Coach, municipalities, local governments, or commercial delivery partners can respond to you and help resolve service issues.
Residents may use the core features of the Recycle Coach application by providing location information only. Providing your name, e-mail address, or mobile phone number is optional and is not required to access core Services.
If you communicate with us by e-mail, web form, support request, or other correspondence, we may collect the information contained in those communications as Personal Information.
Recycle Coach does not collect demographic information such as age or gender through the resident-facing application.
Personal Information is processed only for the purposes described in this Privacy Policy and in accordance with applicable data protection laws.
If you access any Services requiring a username and password, you are solely responsible for keeping those credentials confidential.
4. How We Use Your Information
We use Personal Information and Software Data to provide, operate, support, and maintain the Software and Services and to help municipalities, local governments, and commercial delivery partners deliver local waste and recycling programs.
We use location information (such as your street address and postal or ZIP code) to:
· Determine your correct municipal service area and link you to the appropriate program information.
· Provide you with local waste and recycling schedules, maps, and service information.
· Support location-based features within the Software and Services.
We use optional contact information (such as your name, e-mail address, and/or mobile phone number), where you choose to provide it, to:
· send you service-related reminders and updates about your local waste and recycling program by e-mail, SMS, or automated phone call; and
· respond to your requests, inquiries, and service issues and help Recycle Coach, municipalities, local governments, or commercial delivery partners resolve those issues.
We use Software Data and related technical information (as described in Section 2) to:
· Operate, host, and maintain the Software and Services.
· Secure the Software and Services, prevent misuse, and detect, investigate, or address technical and security issues.
· Understand how the Software and Services are used, support performance and reliability, and maintain and improve user experience, generally using the information in aggregate form for these analytical purposes.
We may also use Personal Information and Software Data to:
· Comply with applicable laws, regulations, and legal processes.
· Enforce our Terms of Use and other agreements.
· Protect the rights, property, or safety of Municipal Media, our users, our partners, or others.
Recycle Coach does not use Personal Information for third-party advertising or for cross-context behavioural advertising or marketing purposes, and does not use Personal Information for unrelated commercial purposes that are not described in this Privacy Policy.
5. How We Collect Software Data and Personal Information
We collect Software Data and Personal Information in a number of ways, depending on how you use the Software and Services.
We may collect information directly from you when you:
· Enter your address or other location information into the Software.
· Choose to provide your name, e-mail address, mobile phone number, or other contact information in connection with reminders, updates, service requests, or support inquiries.
· Communicate with us by e-mail, web form, support request, or other correspondence.
· Otherwise submit information through the Software or Services.
We may collect Software Data automatically as you access and use the Software and Services, including through your browser, device, cookies, and similar technologies, as described in Sections 2 and 6 of this Privacy Policy.
In some cases, we may receive limited information from municipalities, local governments, commercial delivery partners, or other service providers where necessary to deliver, support, or administer local waste and recycling programs, respond to service requests, maintain integrations, or operate the Services.
Where the Software or Services are made available through or embedded within a municipal, local government, partner, or third-party platform, we may also receive information through those channels in connection with your use of the Services.
We collect information only to the extent reasonably necessary for the purposes described in this Privacy Policy and in accordance with applicable law.
6. Cookies and Similar Technologies
Cookies are small text files placed on a user’s device by a website. They are used to enable core website functionality and to collect information about how the website is used.
Recycle Coach uses essential cookies to support the operation of its website and Services, such as maintaining sessions, remembering preferences, and ensuring the website functions correctly. These cookies are necessary for the Services to operate and cannot be disabled through site settings.
Recycle Coach may also use non essential cookies and similar technologies, such as analytics cookies, to collect information about website usage over time. This information is used to understand how users interact with the website, estimate audience size and usage patterns, improve performance, and enhance the user experience. The information collected through these technologies is generally aggregated and statistical in nature.
Recycle Coach does not store user passwords in cookies. Where authentication is required, access is managed through secure session and access controls.
Users may block or delete cookies through their browser settings. Disabling non essential cookies may limit certain website features but does not prevent access to core Services where cookies are required for functionality.
7. Retention and Storage of Information
Recycle Coach retains Personal Information in accordance with its internal data retention policy and the principle of storage limitation, retaining Personal Information for up to 15 years unless a shorter period is required by law or deletion is requested by the individual.
The length of time that Personal Information is retained may vary depending on the nature of the information and the legal, operational, record-keeping, security, and service-related requirements applicable to it.
Unsubscribing from communications will stop future notifications but does not automatically delete contact information. Individuals may request the deletion of their Personal Information at any time through the Recycle Coach website, subject to applicable law and any legal, operational, security, or record-keeping requirements.
Recycle Coach stores and processes Personal Information primarily in Canada for Canada-based and international users, in the United States for U.S.-based users, and in the United Kingdom for UK-based users.
In order to operate and support the Services, Recycle Coach may also use trusted third-party service providers that process limited Personal Information on its behalf from other countries, including jurisdictions where data protection laws may differ from those of the individual’s country of residence.
Where Personal Information is transferred or accessed outside of Canada, the United States, or the United Kingdom, Recycle Coach will take reasonable steps to ensure that appropriate safeguards are in place in accordance with applicable data protection laws. Such safeguards may include contractual confidentiality, security, and data protection obligations, including, where applicable, Standard Contractual Clauses and the UK International Data Transfer Agreement or UK Addendum.
8. Your Privacy Rights
Recycle Coach respects the privacy rights of individuals under applicable data protection laws. Depending on where you live, you may have the right to:
· Request access to the Personal Information we hold about you.
· Request correction of inaccurate or incomplete Personal Information.
· Request deletion of your Personal Information, subject to legal or contractual retention requirements.
· Withdraw consent where our processing is based on consent.
· Request that certain uses of your Personal Information be limited or stopped, where permitted by law.
· Receive an explanation if we are unable to fulfill a request.
Requests may be submitted through the Recycle Coach website. We may take reasonable steps to verify your identity before responding and will respond within the timeframes required by applicable law. If we deny a request, we will explain the reason, subject to legal limitations.
Additional rights or remedies may apply depending on your jurisdiction, including rights available under Canadian privacy laws, the UK GDPR, the EU GDPR, and certain U.S. state privacy laws such as the California Consumer Privacy Act, as amended by the California Privacy Rights Act.
9. Information Sharing and Disclosure
Recycle Coach may share certain categories of Personal Information and Software Data in the ways described in this Privacy Policy.
Recycle Coach may share information with its subsidiaries and affiliates where necessary to operate, support, maintain, secure, or administer the Software and Services.
Recycle Coach may share aggregate, anonymized, or otherwise non-identifiable information with municipalities, local governments, commercial delivery partners, and other service providers for purposes such as service adoption reporting, usage trends, program administration, service planning, and operational improvement.
Recycle Coach may also provide Services in partnership with municipalities, local governments, or commercial delivery partners, and may facilitate contact between residents and those entities to address service requests, respond to inquiries, or resolve service issues. By using the Software and Services and providing us with Personal Information, you understand that Recycle Coach may share Personal Information with those entities where reasonably necessary to respond to your request, provide the Services, or resolve a service issue.
Recycle Coach may share limited Personal Information with trusted third-party service providers that perform services on its behalf, including providers of cloud hosting and infrastructure, communications and notification services, and customer support and ticketing services.
These service providers process Personal Information only in accordance with Recycle Coach’s instructions, are contractually obligated to protect the information, and may not use it for their own purposes.
Recycle Coach may also disclose Personal Information or Software Data where required or permitted by law, including to comply with a court order, legal process, government request, or regulatory requirement, to enforce its Terms of Use or other agreements, or where disclosure is reasonably necessary to protect the rights, property, or safety of Municipal Media, its users, its partners, or others.
Recycle Coach does not disclose Personal Information to third parties for third-party advertising or unrelated commercial purposes. Recycle Coach does not sell Personal Information and does not share Personal Information for cross-context behavioural advertising or marketing purposes, as those terms may be defined under applicable privacy laws. Accordingly, Recycle Coach does not offer a “Do Not Sell or Share My Personal Information” mechanism at this time.
10. Security
The security of your Personal Information is important to Recycle Coach. Recycle Coach uses reasonable administrative, technical, and physical safeguards to protect Personal Information against loss, theft, unauthorized access, copying, use, modification, disclosure, or destruction.These safeguards may include access controls, restricted access to Personal Information, encryption and other security technologies, monitoring, and policies and procedures designed to support the security and confidentiality of the Software and Services.
Recycle Coach maintains an information security program that includes independent assessments, such as SOC 2 audits, and continues to enhance its security controls over time. However, no website, application, device, or method of transmission or storage is completely secure, and Recycle Coach cannot guarantee the absolute security of Personal Information.
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.
If Recycle Coach becomes aware that Personal Information has been disclosed, accessed, or used in a manner not consistent with this Privacy Policy, we will take reasonable steps to assess the incident and will notify affected individuals and, where required, relevant regulatory authorities in accordance with applicable data protection and breach notification laws.
Where Personal Information is processed by trusted third party service providers, those providers are required to notify Recycle Coach of any security incidents involving Personal Information so that Recycle Coach can meet its notification obligations.
The safety and security of your information also depend on you. Where you have been given or have chosen credentials such as username or password to access certain parts of our Services or Software, you are responsible for keeping those credentials confidential and for not sharing them with anyone else. Recycle Coach will never request your password, username, or other sensitive account information by unsolicited e-mail.
11. Lost or Stolen Information
You must promptly notify Recycle Coach if your contact information or account-related information is lost, stolen, or used without your permission. In such circumstances, Recycle Coach may take reasonable steps to update its records and help protect the security of your Personal Information, as appropriate.
12. Integration with Other Software
The Software and Services may contain links to third-party websites, applications, or software components that are not controlled by Recycle Coach.
Except as disclosed in this Privacy Policy, Recycle Coach is not responsible for the privacy practices, content, or security of third-party websites, application, software, or services.
When you access or use third-party websites, applications, or software through or in connection with the Software or Services, your information may also be subject to the privacy policies and terms of those third parties.
Recycle Coach encourages you to review the privacy policies and terms of any third-party websites, applications, or services before providing information to them or using them.
13. Updates and Changes to Privacy Policy
Recycle Coach reviews this Privacy Policy at least annually and may update it from time to time to reflect changes in our practices, technologies, or legal requirements.
When the Privacy Policy is updated, the revised version will be posted on the Recycle Coach website and will become effective as of the date it is posted.
Where changes materially affect how Recycle Coach collects, uses, or discloses Personal Information, Recycle Coach will take reasonable steps to provide advance notice through the Software, the Service, or other applicable channels.
In all cases, use of the information we collect is subject to the Privacy Policy in effect at the time such information is collected.
14. E-mail
You should be aware that e-mail is not an entirely secure medium for transmitting information.
This is important to keep in mind when using e-mail to send or receive Personal Information and “Confidential Information” rather than generic “personal or confidential information” in isolation.
15. Contacts
If you have any questions about this Privacy Policy, want to access or correct your personal information, or wish to make a privacy-related request, you may contact Recycle Coach at:
Privacy Contact
Municipal Media Inc.
50 Carroll St., Ste.
111 Toronto, ON M4M 3G3
Canada
Tel: (800) 598-0988
Email: support@recyclecoach.com
If you have concerns about how Recycle Coach handles Personal Information, you may also contact the privacy regulator that applies to your jurisdiction, including:
Canada (PIPEDA)
Office of the Privacy Commissioner of Canada (OPC)
https://www.priv.gc.ca
•United Kingdom (UK GDPR)
Information Commissioner’s Office (ICO)
https://www.ico.org.uk
•European Union (GDPR)
Your local Data Protection Authority in your EU member state
•California (CCPA / CPRA)
California Privacy Protection Agency (CPPA)
https://cppa.ca.gov
BY USING THE SOFTWARE AND/OR THE SERVICES, YOU ACCEPT THE TERMS OF THIS PRIVACY POLICY IN ITS ENTIRETY WITHOUT ANY MODIFICATION.
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