1. Who are we?
Hibou is a lifestyle service offered as a cloud based software solution under the classification of a personal emergency response system. We aim at supporting adults in maintaining an active and independent lifestyle throughout their lives. We manage this by reducing fear and risk when participating in activities alone by using Pro-Active Check-ins, Help Buttons, environmental feedback and cues.
2. What personal information do we collect?
Canadian privacy legislation defines personal information broadly as information about “an identifiable individual” or as information that allows an individual to be identified. The types of personal information that we may collect from you from time to time include: your name, address, telephone number, e-mail address, your alternate telephone number (e.g. during a vacation), payment information (for billing purposes), your billing preferences (such as “quarterly”, “monthly”, etc.). In addition, from time to time, we may ask you to provide us with more detailed information regarding your, occupation, and contact information.
3. Why do we collect your personal information?
We collect your personal information for the purposes listed below:
(a) To provide the product, service or information you requested
If you are a customer of one of our services, we use your name, telephone numbers and address (postal and/or e-mail) in order to deliver the product, service or information you requested and to follow up with you about the transaction (i.e., send a bill, notify you that your subscription is expiring, etc.).
(b) To process payment
Your credit card number, debit card number, or banking information for pre-authorized payments is used only for processing payments and for presenting you with payment options – not for marketing purposes.
(c) To send you information
From time to time we may send you further information about our company, its offers, or other products produced under its name.
(d) Other purposes
In addition, from time to time, we may use your personal information for the following purposes:
- to detect and protect Hibou and other third parties against error, fraud, theft and other illegal activity, and to audit compliance with Hibou policies and contractual obligations;
- to understand your needs and preferences, including to contact and communicate with you and to conduct surveys, research and evaluations;
- to obtain audited statements regarding numbers of subscribers per service;
- to engage in business transactions, including the purchase, sale, lease, merger, amalgamation or any other type of acquisition, disposal, securitization or financing involving Hibou;
- for any other purpose we may indicate to you from time to time.
4. To whom do we disclose your personal information?
We may disclose your personal information to the following third parties in the following circumstances:
- (a) Disclosure to Service Providers We may disclose your personal information to other companies that provide services on our behalf, including label printers, invoice printers, fulfillment contractors, auditors, our software developers (including website developers and hosts), data processing, document management and office services. In addition, we may disclose your personal information to an organization or individual retained by Hibou to evaluate your creditworthiness or to collect debts outstanding on an account or to our auditors. We will only provide those companies the information they need to deliver the service and they are prohibited from using that information for any other purpose.
- (b) Disclosure to Affiliates and Business Units We may disclose your personal information to any of the companies and business units that form part of the Hibou group (i.e. amongst Hibou Application Ltd., its subsidiaries and affiliates) in order to serve you better and to provide you with information about our group’s products and services.
- (d) Law Enforcement and Legal Disclosure Hibou may disclose your personal information to a government institution that has asserted its lawful authority to obtain the information or where Hibou has reasonable grounds to believe the information could be useful in the investigation of unlawful activity, or to comply with a subpoena or warrant or an order made by a court, person or body with jurisdiction to compel the production of information, or to comply with court rules regarding the production of records and information, or to Hibou’s legal counsel.
If you would prefer for us NOT to share your information as described above in sections 4(a)-4(d), simply inform us (see “Contact Us” below).
5. Control of your personal information
At Hibou, we want you to be able to maintain control over how we use your personal information. In particular:
- You may have the right to “opt out” of some or all of the identified purposes, uses and disclosures listed in sections 3 and 4 above.
- You always have the option to instruct us not to use your name, address, e-mail address, etc. beyond providing you with the product, service or information you requested. See “Contact Us” below.
- E-mail communications will always include an identification of the sender.
As mentioned above, we may not be able to provide you with our services if you withdraw your consent to our use of your personal information.
6. Where is your personal information stored?
Your personal information is stored in secured locations and on servers controlled by Hibou, located either at our offices or at the offices of our service providers. For access to your personal information, please contact our Chief Privacy Officer using the contact information in the “Contact Us” section below.
7. How can you access your personal information?
Upon written request, subject to certain exceptions, Hibou will inform you of the existence, use, and disclosure of your personal information and will give you access to that information. Access requests should be sent to our Chief Privacy Officer, using the contact information in the “Contact Us” section below.
8. How do we protect your personal information?
We make every reasonable effort to protect against the loss, misuse, and alteration of personal information under our control. Our security policies are periodically reviewed and enhanced as necessary.
Only authorized employees and suppliers have access to your personal information. Where information is sent to a third party for processing, we make sure, through our contracts with them, that all your information is kept secure. We keep your information for the time we are providing you with a product or service, and for a reasonable time thereafter in the event that you wish to resume service.
We operate secure data networks protected by industry standard firewall and password protection systems. Credit card information is processed using industry-standard encryption and security. We do not collect personal information from bulletin boards or forums. However, we cannot guarantee that personal information voluntarily disclosed in chat rooms or discussion boards will not be collected and used by others, which may result in unsolicited messages to you from other parties.
9. Privacy and our websites
Hibou sometimes collects personal information through its various websites. In this section, we provide you with additional information regarding such collection.
Online Communications – In order to provide our website visitors with a product, service or information, visitors may voluntarily submit personal information to us for purposes such as asking a question, obtaining information, subscribing to, reviewing or downloading a publication, participating in contests and surveys. If you are known to Hibou as a registered user of an online service, we may combine and store personal information about your use of our websites and the online information you have provided with certain other online and offline information we may have collected.
E-Mail Communications – Occasionally, we may send marketing or promotional e-mail communications to you with information that may be useful, including information about the products and services of Hibou and other third parties with whom we have a relationship. We will include instructions on how to inform us of preferences if recipients decide they do not want to receive any future marketing or promotional e-mails from Hibou.
Also, if you send us an email message, we may retain that message and your email address, as well as any response we send you.
Searches – For your convenience, search functions are sometimes provided on our websites. We keep logs of the words searched to learn more about what kind of information our visitors are seeking, and thus improve our services.
Hyperlinks – For your convenience, Hibou’s websites sometimes contain hyperlinks to websites managed by third parties. By activating these hyperlinks, you will leave Hibou’s websites for those of the third parties, which may have different privacy policies and practices than Hibou. Hibou cannot be held liable for the use of such third party websites.
Advertising to Children – We believe that none of Hibou’s websites appeal directly to children of 13 years old or less. We do not knowingly direct our advertising at children under the age of 13, except as permitted by law.
Individuals Under 18 – No personal information should be submitted or posted on our websites by individuals under 18 years of age without their parent’s or guardian’s permission. We may request name, address, phone number, email address and date of birth from an individual under 18 years of age for contest participation so that we may notify him or her if selected as a winner. In the event we do so, we will request their parent’s or guardian’s consent prior to collection.
No information collected from online guests under 18 years of age is used for any marketing or promotional purposes whatsoever by Hibou. Unless otherwise disclosed at collection, we do not provide any personal information collected through any Hibou website from individuals under 18 years old, regardless of its source, to any third party for any purpose whatsoever.
11. Contact Us
Hibou Chief Privacy Officer
201 – 1523 East Pender Street
Vancouver, BC, V5L 1V9
What are “fair information practices”?
In Canada, “fair information practices” with regards to your personal information are reflected in a series of principles developed by the Canadian Standards Association and incorporated into Canadian privacy legislation, designed to ensure that companies treat your personal information fairly, protect its confidentiality and provide the means by which individuals can maintain a reasonable level of control over how their personal information is collected, used and disclosed. Hibou collects, uses and discloses your personal information by employing “fair information practices” as described in the following ten privacy principles:
Principle 1 – Accountability
Principle 2 – Identifying the Purposes for Collection of Personal Information
Principle 3 – Obtaining Consent for Collection, Use or Disclosure of Personal Information
Principle 4 – Limiting Collection of Personal Information
Hibou will limit the collection of personal information, both the amount and the type of information, to that which is necessary for the purposes identified by Hibou. In addition, Hibou will collect your personal information by fair and lawful means, and not by misleading or deceiving you about the purpose for which information is being collected.
Principle 5 – Limiting Use, Disclosure, and Retention of Personal Information
Hibou will not use or disclose personal information for purposes other than the identified purposes for which it was collected, except with your consent or as required or permitted by law. Hibou will retain your personal information only as long as necessary to fulfil the identified purposes.
Principle 6 – Accuracy of Personal Information
Hibou will endeavour to ensure that your personal information will be as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used. Hibou will update personal information as and when necessary to fulfill the identified purposes or upon notification from the subject individual. Hibou will not routinely update personal information, unless such process is necessary to fulfill the identified purposes. If ever your contact and/or other personal information changes, please feel free to contact us, so that we can update our records.
Principle 7 – Security Safeguards
Hibou will protect your personal information by security safeguards appropriate to the sensitivity of the information. For example, the computer servers on which we store your personal information are protected by firewalls and other industry standard security features. In addition, your personal information is only made available to our employees and service providers who have a “need to know” in order to offer you our services or otherwise fulfil the purposes identified in Section 3 above.
Principle 8 – Openness Concerning Policies and Practices
Principle 9 – Individual Access to Personal Information
Upon written request, subject to certain exceptions, Hibou will inform you of the existence, use, and disclosure of your personal information and will give you access to that information. If access is denied, Hibou will notify you in writing, give reasons for the denial, and inform you of the recourses open to you. If access is granted, Hibou will give you a reasonable opportunity to review your personal information. You will be able to challenge the accuracy and completeness of the information and have it amended as appropriate.
Principle 10 – Challenging Compliance