Mobtreal.com (“Mobtreal.com”) is strongly committed
(“Site”), is used only in the manner and for the purposes described
Limiting Use, Disclosure and Retention
PRINCIPLE #1 – ACCOUNTABILITY
Mobtreal.com is responsible for personal information under its control and will designate an individual or individuals who are accountable for the organization’s compliance with the following principles.
1.1 Accountability for Mobtreal.com‘s compliance with the principles rests with the senior management of Mobtreal.com and the person or persons designated by senior management as Privacy Officer, even though other individuals within the organization may be responsible for the day-to-day collection and processing of personal information. In addition, other individuals within
the organization may be delegated to act on behalf of senior management or the Privacy Officer.
1.2 Mobtreal.com Privacy Officer may be contacted at:
Attention: Mobtreal.com c/o Privacy Officer
1487 Bayview Ave
1.3. Mobtreal.com is responsible for personal information in its possession or custody, including information that has been transferred to a third party for processing. Mobtreal.com will use contractual or other means to provide a comparable level of protection while the information is being processed by a third party.
1.4 Mobtreal.com will implement policies and practices to give effect to these principles, including: implementing procedures to protect personal information; establishing procedures to receive and respond to complaints and inquiries; training staff and communicating to staff information about Mobtreal.com‘s policies and practices; and developing information to explain Mobtreal.com‘s policies and procedures.
PRINCIPLE #2 – IDENTIFYING PURPOSES
Mobtreal.com will identify the purposes for which personal information is collected at or before the time the information is collected.
2.1 Mobtreal.com collects personal information only for the following purposes (“identified purposes”): to provide service(s) and/or products to its customers; to maintain commercial relations and to communicate with its customers (which will include, but not be limited to: billing, collection, advertising, promotion,
account verification); to evaluate customers’ financial status and eligibility for credit; to identify customer needs and/or preferences;
to meet legal and regulatory requirements; to administer and manage its business operations; and as otherwise required or permitted by law
2.2 Mobtreal.com will provide notice of the identified purposes either orally, electronically or in writing prior to or at the time of collection of the personal information.
2.3 If individual persons collect personal information, they will be able to specify the purposes for which the information is being collected, or will refer the individual whose information is being collected to a designated person at Mobtreal.com who will specify the purposes.
2.4 When personal information that previously has been collected is to be used for a purpose not previously identified, the new purpose will be identified prior to use. Unless the new purpose is required by law, and subject to the exceptions referred to in Principle #3, Mobtreal.com will obtain the consent of the individual before information is used for that new purpose.
2.5 Occasionally, Mobtreal.com will communicate to you special bonus and new product offers that we think may be of value to you. Mobtreal.com may retain third parties to assist it in marketing such new or additional Mobtreal.com products and services to our customers (and for such purpose may share personal
information with such third parties) but will not otherwise disclose or make
available any personal information to any third parties seeking to market their products to Mobtreal.com‘s customers. All Mobtreal.com customers have the right to chose not to participate in direct marketing of new products and services from Mobtreal.com. If you wish to opt-out of receiving targeted communications from Mobtreal.com in electronic,
printed or verbal format (other than information included with your monthly bills), simply inform us in writing at:
c/o Privacy Officer
1487 Bayview Ave.
Toronto, On. Canada
2.6 The Site may provide hyperlinks, which are highlighted words or pictures within a hypertext document that may, when clicked, take you to another place within the document, to another document altogether, or to a third party website not controlled by Mobtreal.com. Such hyperlinked third party websites
may collect and disclose information different than this Site. Mobtreal.com is not responsible for the collection, use, or disclosure of information collected through these third party web sites, and Mobtreal.com expressly disclaims any and all liability related to such collection, use, or disclosure.
PRINCIPLE #3 – CONSENT
The knowledge and consent of the individual are required for the collection,
use or disclosure of personal information, except where inappropriate.
3.1 In certain circumstances, personal information can be collected, used,
or disclosed without the knowledge and consent of the individual. For example,
where collection or use is clearly in the interests of the individual and consent
cannot be obtained in a timely way; where used or disclosed in the case of an
emergency that threatens the life, health or security of an individual; where
personal information is publicly available as defined by regulation; where collection
with knowledge or consent might compromise the availability or accuracy of the
information and the collection relates to investigation of a breach of agreement
or contravention of law; and where disclosed for debt collection purposes or
to comply with a subpoena, warrant or court order.
3.2 Where required, Mobtreal.com will generally seek consent for the
use or disclosure of the information at the time of collection. In certain circumstances,
consent with respect to use or disclosure may be sought after the information
has been collected but before use (for example, when Mobtreal.com wants
to use information for a purpose not previously identified).
3.3 Mobtreal.com will make a reasonable effort to ensure that the
individual is advised of the purposes for which the information will be used.
To make the consent meaningful, the purposes will be stated in such a manner
that the individual can reasonably understand how the information will be used
3.4 Mobtreal.com will not, as a condition of the supply of a product
or service, require an individual to consent to the collection, use, or disclosure
of information beyond that required to fulfill the explicitly specified and
3.5 The form of consent sought by Mobtreal.com may vary, depending
upon the circumstances and the type of information disclosed. Mobtreal.com
will seek express consent when the information is likely to be considered sensitive.
Implied consent will generally be appropriate when the information is less sensitive.
3.6 An individual may withdraw consent at any time, subject to legal or contractual
restrictions and reasonable notice. Mobtreal.com will inform the individual
of the implications of such withdrawal. In order to withdraw consent, an individual
must provide notice to Mobtreal.com in writing.
3.7 With respect to personal information already collected by Mobtreal.com
reasonable notice to Mobtreal.com‘s current customers of the
purposes and uses for which such personal information has been collected. Should
an individual object to these ongoing uses or disclosures, consent may be withdrawn
upon providing notice to Mobtreal.com in writing.
PRINCIPLE #4 – LIMITING COLLECTION
The collection of personal information will be limited to that which is necessary
for the purposes identified by Mobtreal.com. Information will be collected
by fair and lawful means.
4.1 Mobtreal.com collects personal information from its customers
for the purposes described under Principle #2.
4.2 Mobtreal.com may also collect personal information from such third
parties as credit bureaus, employers or personal references or other third parties
that represent that they have the right to disclose the information.
4.3 The Site uses a feature of Internet web browsers called a cookie, which
is a file that is sent to your browser from the Site’s computers and stored
on your computer’s hard drive. A cookie assigns a unique identification
code to your computer in order to collect anonymous information. On this Site,
cookies are used to help us track visitors, conduct research and improve our
content and services.
Mobtreal.com‘s cookies do not collect personal information.
Mobtreal.com only collects personal information if you knowingly and
willingly provide such information.
You may set your Internet web browser to notify you when you receive a cookie
or to prevent cookies from being sent. If you prevent a cookie from being sent,
you may limit the functionality of the Site.
PRINCIPLE #5 – LIMITING USE, DISCLOSURE, AND RETENTION
Personal information will not be used or disclosed for purposes other than
those for which it was collected, except with the consent of the individual
or as otherwise required or permitted by law. Personal information will be retained
only as long as necessary for the fulfillment of those purposes or as otherwise
required or permitted by law.
5.1 Mobtreal.com may collect, use or disclose personal information
without the individual’s knowledge or consent in certain circumstances
as described in Principle #3.1.
5.2 Mobtreal.com may disclose a customer’s personal information
Our contracted agency or company or personnel involved in the development,
promotion, marketing or enhancement of Mobtreal.com products and services;
5.3 Personal information may also be disclosed in connection with a sale, transfer
or reorganization of one or more of Mobtreal.com‘s businesses,
in which case Mobtreal.com will require that any personal information
permitted by law.
5.4 Mobtreal.com will retain personal information that has been used
to make a decision about an individual long enough to allow the individual access
to the information after the decision has been made, and, in the event of an
access request or a challenge, long enough to exhaust any recourse an individual
may have under the law.
PRINCIPLE #6 – ACCURACY
Personal information will be updated as necessary for the purposes for which
it is to be collected and used.
6.1 The extent to which personal information will be updated will depend upon
the use of the information, taking into account the interests of the individual.
Information will be sufficiently accurate, complete, and up-to-date to minimize
the possibility that inappropriate information may be used to make a decision
about the individual.
6.2 Mobtreal.com will not routinely update personal information unless
such a process is necessary to fulfill the purposes for which the information
6.3 Personal information that is used on an ongoing basis, including information
that is disclosed to third parties, will generally be accurate and up-to-date
to the best of Mobtreal.com‘s knowledge, unless limits to the
requirement for accuracy are clearly set out.
PRINCIPLE #7 – SAFEGUARDS
Mobtreal.com will use reasonable efforts to protect personal information
by security safeguards appropriate to the sensitivity of the information.
7.1 Mobtreal.com has invested and deployed a wide variety of technology
and security features to ensure the privacy of personal and anonymous information
on its network. In addition, Mobtreal.com has implemented strict operations
guidelines to safeguard customer privacy at every level of its organization.
Mobtreal.com will continue to revise policies and implement additional
security features as new technologies become available.
Unfortunately, no system is perfect; therefore, Mobtreal.com makes
no representations or warranties with regard to the sufficiency of these security
measures. Mobtreal.com shall not be responsible for any actual or consequential
damages (or any other damages or liability of any kind whatsoever, whether as
a result of negligence or otherwise) that result from a lapse in compliance
with this Policy because of a security breach or technical malfunction.
7.2 Mobtreal.com protects all personal information regardless of the
format in which it is held. The methods of protection include:
physical measures, such as locked filing cabinets and restricted access to
organizational measures, such as security clearances and limiting access on
a “need to know” basis;
technological measures, such as the use of passwords and encryption.
7.3 Mobtreal.com makes their employees aware of the importance of
maintaining the confidentiality of personal information. Mobtreal.com
employees are governed by non-disclosure obligations. These obligations prohibit
disclosure or use of any confidential or personal information except in accordance
PRINCIPLE #8 – OPENNESS
Mobtreal.com will, upon written request, make readily available to
individuals specific information about its policies and practices relating to
the management of personal information, other than confidential commercial information.
8.1 Mobtreal.com will make its policies and practices with respect
to the management of personal information comprehensible and accessible, by
providing upon request:
the name, title, and address of the Privacy Officer accountable for Mobtreal.com‘s
policies and practices and to whom complaints or inquiries can be forwarded;
the means by which an individual can gain access to his or her personal information
held by Mobtreal.com; and
a description of the type of information held by Mobtreal.com and/or
its subsidiaries, including a general account of its use.
PRINCIPLE #9 – INDIVIDUAL ACCESS
Upon written request, an individual will be informed of the existence, use,
and disclosure of his or her personal information and will be given access to
that information. An individual will be able to challenge the accuracy and completeness
of the information and have it amended as appropriate.
9.1 Upon written request, Mobtreal.com will inform an individual whether
or not the organization holds personal information about that individual, and
will provide that individual with a reasonable opportunity to review the personal
information in his or her file.
9.2 Mobtreal.com will allow the individual access to his or her personal
information once the individual has provided Mobtreal.com with a written
request application. The application will include sufficient information to
permit Mobtreal.com to provide an account of the existence, use, and
disclosure to any third parties of this personal information. Mobtreal.com
will use the application only for this purpose.
9.3 Mobtreal.com will respond to an individual’s written request
within 30 days, unless this period is extended in accordance with applicable
legislation, in which case notice will be sent to the individual within 30 days
regarding the extension, the reasons for it and the individual’s rights
in connection with it. Mobtreal.com will assist any individual who
informs it that they need assistance in preparing a request. While the response
will typically be provided at no cost to the individual, depending on the nature
of the request and the amount of information involved, Mobtreal.com
reserves the right to impose a cost. In these circumstances, Mobtreal.com
will inform the individual of the approximate cost to provide the response and
proceed upon payment. The requested information will be provided or made available
in a form that is generally understandable.
9.4 Mobtreal.com will be as specific as possible in providing an account
of third parties to which it has disclosed personal information about an individual.
When it is not possible to provide a list of the organizations to which it has
actually disclosed information about an individual, Mobtreal.com will
provide a list of organizations to which it may have disclosed information about
9.5 In certain instances, Mobtreal.com will not be able to provide
the individual access to his or her personal information. Where permitted, the
reasons for denying access will be provided to the individual. This will be
done upon the individual’s request, unless Mobtreal.com is required
by law to provide such written reasons. Exceptions to the grant of an access
request may include: information that contains references to other individuals
or contains confidential commercial information, where such information cannot
be severed from the record; information protected by solicitor-client privilege;
information properly collected without the knowledge or consent of the individual
for purposes related to investigating a breach of an agreement or a contravention
of law; information generated in the course of a formal dispute resolution process;
and as required or permitted by law.
9.6 When an individual successfully demonstrates the inaccuracy or incompleteness
of personal information, Mobtreal.com will amend the information as
required. Depending upon the nature of the information challenged, amendment
may involve the correction, deletion or addition of information. Where appropriate,
the amended information will be transmitted to third parties having access to
the information in question.
9.7 When a challenge is not resolved to the satisfaction of the individual,
Mobtreal.com will record the substance of the unresolved challenge.
When appropriate in Mobtreal.com’s judgment, the unresolved challenge
will be transmitted to third parties having access to the information in question.
PRINCIPLE #10 – CHALLENGING COMPLIANCE
An individual will be able to address a challenge concerning compliance with
the above principles to Mobtreal.com‘s Privacy Officer.
10.1 Mobtreal.com will maintain procedures to receive and respond
to complaints or inquiries about its policies and practices relating to the
handling of personal information.
10.2 Mobtreal.com will inform individuals who make inquiries or lodge
complaints of the existence of relevant complaint procedures.
may seek external advice where appropriate before providing a final response
to individual complaints.
10.4 Mobtreal.com will investigate all complaints. If a complaint
is found to be justified, Mobtreal.com will take appropriate measures,
including, if necessary, amending its policies and practices.