MyKarma Mobile App Privacy Policy
1. INTRODUCTION
Karma Technologies (Canada) Inc. (“Karma”, “MyKarma”, “Company” or ”We”) respect your privacy and are committed to protecting it by complying with this policy.
This policy describes:
- The types of information we may collect or that app users (“you” or “Users”) may provide when you download, install, register with, access, or use the MyKarma mobile application (the “MyKarma App” or “App”) or access our website at www.getmykarma.ca (our “Site” or “Website”), as well as through any products and services we offer through our App or Site, or otherwise make available to you (collectively the ‘MyKarma Services’ or ‘Services’).
- Our practices for collecting, using, maintaining, protecting, and disclosing that information.
We will only use your personal information in accordance with this policy unless otherwise required by applicable law. We take steps to ensure that the personal information that we collect about you is adequate, relevant, not excessive, and used for limited purposes.
Note that privacy laws in Canada generally define “personal information” as any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person but does not include business contact information (including your name, title, or business contact details.) We are committed to protecting any personal information that is collected by us in connection with the Services and adhering to all applicable privacy legislation, including British Columbia’s Personal Information Protection Act (“PIPA”), Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”), the Canadian Standards Association’s Model Code for the Protection of Personal Information, Canadian Anti-Spam Legislation (“CASL”), the US Federal Trade Commission Act, the Gramm-Leach-Bliley Act 15 USC S6801, and US Federal law, including the Electronic Government (E-GOV) Act of 2002 and the Privacy Act of 1974. We are committed to maintaining the accuracy, confidentiality and security of your personal information. As part of this commitment, we are guided by the principles set out in both PIPA and PIPEDA.
1.1 What Information Does This Policy Apply To?
This policy applies only to information we collect in this App and in email, text, and other electronic communications sent through or in connection with this App.
This policy DOES NOT apply to information that:
- We collect offline or on any other Company apps or websites, including websites you may access through this App.
- You provide to or is collected by any third party (see Third-Party Information Collection).
- You provide as a result of your participation in any affiliate marketing networks, or which you provide to third-party publishers participating in such networks.
Our websites and apps – and any third parties you encounter through your use of such – may have their own privacy policies, which we encourage you to read before providing information on or through them.
Please read this policy carefully to understand our policies and practices for collecting, processing, and storing your information. If you do not agree with our policies and practices, do not download, register with, or use this App. By downloading, registering with, or using this App, you indicate that you understand, accept, and consent to the practices described in this privacy policy. You authorize us to use and retain this personal information for as long as it may be required for the purposes described herein. Consent may also be obtained by us in writing or verbally, in person or over the phone. Such consent remains valid even after the termination of our relationship with you, unless you provide us with written notice that such consent is xawn. If such consent is withdrawn, we will comply with your request, except where such withdrawal would frustrate a legal obligation. This policy may change from time to time (see ‘Changes to Our Privacy Policy’ below). Your continued use of this App after we make changes indicates that you accept and consent to those changes, so please check the policy periodically for updates. We will notify you in advance of any material changes to this policy and obtain your consent to any new ways that we collect, use, and disclose your personal information.
You agree to indemnify and hold harmless Karma, its affiliates, partners, directors, officers, agents and suppliers from and against any and all claims, suits, proceedings, liabilities, damages, losses, fees and expenses (including reasonable attorneys’ fees) arising out of or in relation to any claims resulting from your breach of the Terms and Conditions, this Privacy Policy or your use of the MyKarma Platform.
To withdraw your consent, please contact our Privacy Officer at the below contact details:
Neil Hayden – Privacy Officer, MyKarma
Email: privacy@getmykarma.ca
Phone: +1 888 618 6848
2. INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT
We collect information about you through:
- Direct interactions with you when you provide information to us, such as:some text
- filling in forms or otherwise corresponding with us, for example by contacting us with questions or complaints;
- visiting or using our website;
- registering for or using the MyKarma App, including information about your transactions and activity on our App;
- in connection with other activities, services, features or resources we make available on or through our App or website;
- we may also collect personal information from third parties with your consent.
- Automated technologies or interactions, when you interact with our website or use the App, for example, we may collect information such as usage details, IP addresses, and information collected through cookies, web beacons and other tracking technologies.
The types of information that we collect include:
- Personal information that we can reasonably use to directly or indirectly identify you, such as your name, mailing address, email address, telephone number, internet protocol (IP) address, username or other similar identifier, billing and account information, government issued ID information, social insurance number, payroll provider, occupation, employer or other related organization, banking or other account information, and any other identifier we may use to contact you (“personal information”).
- Non-personal information that does not directly or indirectly reveal your identity or directly relate to an identified individual, such as demographic information, or statistical or aggregated information. We may derive non-personal statistical or aggregated data from personal information. For example, we may aggregate personal information to calculate the percentage of users accessing a specific app feature.
- Technical information, including your login information, device type, time zone setting, and usage details.
We provide an opportunity for any user to close their MyKarma account by using the delete account feature in the user settings section of our App. Users may also opt-out of contact for marketing purposes on an ongoing basis by emailing hello@getmykarma.ca with ‘unsubscribe’ in the subject line, or by using the unsubscribe link at the bottom of our communications, where applicable.
Information You Provide to Us
When you download, register with, or use the MyKarma App, we may ask you to provide:
- Information by filling in forms in the App. This includes information you provide when registering a user account to use our App or requesting further services we make available. We may also ask you for information when you enter a contest or promotion sponsored by us and when you report a problem with the App.
- Records and copies of your correspondence, including email addresses and phone numbers, if you contact us.
- Your responses to surveys that we might ask you to complete for research or other purposes.
- Details of transactions you carry out through the App and order fulfillment. We may require you to provide financial information before completing a transaction through the App.
- Your search queries on the App.
By creating a user account, you (i) agree that we may verify your name, address, phone number, and other account details with information from third-party or publicly available sources (e.g., identity verification providers, fraud prevention services, government registries, and your mobile service provider) to verify your identity and protect against fraud, and (ii) you consent to these third parties disclosing and/or comparing your information for this purpose. Your personal information will not be shared with these third parties for any other reason.
Automatic Information Collection and Tracking Technologies
When you access or use our Website, it may automatically collect information such as the name of your browser, type of computer and technical information about your means of accessing our Site such as the operating system and Internet Service Provider (ISP) utilized by you and other similar information. We use this information to understand how our site is interacted with and to make improvements.
When you download, access, and use the MyKarma App, it may automatically collect:
- Usage details. When you access and use the App, we may automatically collect certain details of your access to and use of the App, including traffic data, location data, logs, and other communication data and the resources that you access and use on or through the App.
- Device information. We may collect information about your mobile device and internet connection, including the device's unique device identifier, IP address, operating system, browser type, mobile network information, and the device's telephone number.
- Stored information and files. The App also may access metadata and other information associated with other files stored on your device. This may include, for example, photographs, audio and video clips, personal contacts, and address book information.
- Location information. This App may collect real-time information about the location of your device. When you use the services in our App, for example by making a transaction, we may collect information on the location it took place.
The technologies we use for this automatic data collection may include:
- Cookies (or mobile cookies). A cookie is a small file placed on your computer or smartphone. It may be possible to refuse to accept cookies by activating the appropriate setting on your device. However, if you select this setting you may be unable to access certain parts of our App.
- Web beacons. Pages of the App, Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related app statistics (for example, recording the popularity of certain app content and verifying system and server integrity).
We may also use these technologies to collect information about your activities over time and across third-party websites, apps or other online services (behavioural tracking). To learn more or to opt-out of tailored advertising please visit the Digital Advertising Alliance of Canada Opt-Out Tool for information on how you can opt out of behavioural tracking on or through this App and how we respond to browser signals and other mechanisms that help users exercise their choices about behavioural tracking.
The information we collect automatically is statistical information and may include personal information. We may maintain it or associate it with personal information we collect in other ways, that you provide to us, or that we receive from third parties. This usage information helps us to improve our App and to deliver a more personalized service, including by helping us to:
- Estimate our audience size and usage patterns.
- Store information about your preferences and customize our App according to your individual interests.
- Speed up your searches.
- Recognize you when you use the App.
If you do not want us to collect this information do not download the App or delete it from your device. Users may also opt-out of contact for marketing purposes on an ongoing basis by emailing hello@getmykarma.ca with ‘Unsubscribe’ in the subject line, or by using the unsubscribe link at the bottom of our communications, where applicable. For more information, see the ‘How We Use Your Information’ and ‘Disclosure of Your Information’ sections below. Note, however, that opting out of the App's collection of location information will cause its location-based features to be disabled.
Third-Party Information Collection
When you use our Website or our App or its content, certain third parties may collect information about you or your device. These third parties may include:
- Advertisers, ad networks, and ad servers on our Site or others.
- Analytics companies.
- Third-party services or publishers whom you may connect to through our App.
- Businesses and merchants we make available for you to transact with in our App.
- Your mobile device manufacturer, ISP Provider and mobile service provider.
These third parties may use cookies or other tracking technologies to collect information about you when you use the App. The information they collect may be associated with your personal information. They may use this information to provide you with behavioural advertising or other targeted content.
You can opt-out of several third party ad servers' and networks' cookies simultaneously by using a the Digital Advertising Alliance of Canada Opt-Out Tool . You can also access these websites to learn more about online behavioural advertising and how to stop websites from placing cookies on your device. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.
We do not control these third parties' tracking technologies or how they use them. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For more information about how you can opt out of receiving targeted advertising from many providers, see ‘Choices About Your Personal Information’ below.
HOW WE USE YOUR INFORMATION
We use information that we collect about you or that you provide to us, including any personal information:
- To provide you with the App and its contents and register you as a User of our Services.
- To provide you with and administer any information, products or Services that you request from us, and to resolve any issues relating to them.
- To fulfill the purposes for which you provided it or that were described when it was collected or any other purpose for which you provide it.
- To provide notices about your account, including expiration and renewal notices.
- To carry out our obligations and enforce our rights in any contracts with you, including for billing and collection or to comply with legal or regulatory requirements.
- To notify you when App updates are available, and of changes to any products or services we offer or provide though it.
- To improve our App, products or Services, or customer relationships and experiences, which may include personalizing a User’s experience when they use the App or Services.
- For marketing purposes.
- To generate aggregate or de-identified data, which once created is not capable of identifying you individually. We may use aggregate and de-identified data for research and analytics or any other lawful purpose.
- For other reasonable business purposes connected to our provision of the App and Services, including fraud detection and prevention, legal compliance and to maintain business records.
- To measure or understand the effectiveness of the advertising we serve to you and others, and to deliver relevant advertising to you.
- For any other purpose with your informed consent or as permitted or required by law.
Usage information that we collect helps us to improve our App and to deliver a better and more personalized experience, including by enabling us to:
- Estimate our audience size and usage patterns.
- Store information about your preferences, allowing us to customize our App according to your individual interests.
- Speed up your searches.
- Recognize you when you use the App.
We use location information we collect to ensure the utility of the Services made available to you in and through the App. For example, we may use your location to filter out offer at retailers who do not have a presence in your city or province. If you choose to opt out of location based tracking, please ensure you update your location if you are accessing the App and/or Services from a different City than is listed in your User registration information.
We may also use your information to contact you about our own and third parties' goods and services that may be of interest to you via in-App push notifications or email, or otherwise, as permitted by law. If you do not want us to use your information in this way, please adjust your user preferences in your account profile or email us at hello@getmykarma.ca. If applicable, you may also use the unsubscribe mechanism at the bottom of our emails to stop this form of messaging. For more information, see ‘Choices About Your Personal Information’ below.
We may use the information we have collected from you to display advertisements to our advertisers' target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.
DISCLOSURE OF YOUR INFORMATION
We may share aggregated information about our Users that does not identify any individual, and other information not linked to any personally identifying information regarding Site visitors and App Users with our business partners, subsidiaries, affiliated and advertisers or the purposes outlined above.
We may disclose personal information that we collect or you provide as described in this privacy policy:
- To third parties (which may include third parties outside of Canada) as necessary to provide the Services which you, as a User, have requested. This may include sharing information with third parties such as banking partners, identity verification providers, fraud prevention services, government agencies and mobile service providers in order to verify your identity and contact and account details and protect you from fraud.
We may disclose your personal information and payment history to credit bureaus for the purposes of updating and maintaining the information in their records for certain products or services offered through our App, the registration process for which contains greater detail on such disclosure.
- In connection with a proposed or actual financing, securitization, or insuring, as well as to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Karma Technologies (Canada) Inc.'s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Karma Technologies (Canada) Inc. about our customers and users is among the assets transferred.
- To advertisers and advertising networks that require the information to select and serve relevant advertisements to you and others. We may also use such aggregate information to help advertisers target a specific audience (for example, men in a specific location). We may use the personal information we collect from you to display our advertisers' advertisements to their target audiences.
- To third parties to market their products or services to you if you have consented to these disclosures. For more information, see Choices About How We Use and Disclose Your Information].
- To service providers and other third parties we use to support our business, such as analytics and search engine providers that help us optimize and improve our services. This may include providers we use to perform specialized services on our behalf, including data hosting or processing, research and analytics, marketing or mail distribution, digital support, customer service, and banking and payment processing services. We provide these third parties with only the information necessary to perform their contracted services, and contractually require them to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process personal information in a manner that consistent with standards set out in this Privacy Policy.
- To fulfill the purpose for which you provided it, or for any other purpose we disclose when you provide the information.
- In other circumstances with your consent.
- To comply with any court order, law, or legal process, including to respond to any government or regulatory request or as otherwise required by law, including foreign laws applicable to use, our affiliates and our service providers.
- To enforce our rights arising from any contracts between you and us, including the MyKarma App’s Terms of Use of and for billing and collection, as applicable.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Karma Technologies (Canada) Inc., our customers, or others. This includes exchanging information with other companies and organizations for fraud prevention and credit risk reduction.
TRANSFERRING YOUR PERSONAL INFORMATION
We may transfer personal information that we collect or that you provide us to contractors, service providers, and other third parties we use to support the App (as detailed under Disclosure of Your Information above). We only provide them with the information necessary to perform services and they are contractually obligated to keep personal information confidential, to use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy.
We may process, store, and transfer your personal information in and to jurisdictions other than the jurisdiction in which the information was originally collected. Your personal information may be processed and stored outside of your jurisdiction of residence, including jurisdictions outside of Canada with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information. Whenever we engage a service provider, we require that its privacy and security standards comply with this policy and applicable Canadian laws.
By submitting your personal information or engaging with the App, you consent to this transfer, storage, or processing.
CHOICES ABOUT YOUR PERSONAL INFORMATION
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
- Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies or block the use of other tracking technologies some parts of this App may not be accessible or may not function properly. For more information about tracking technologies, see Automatic Information Collection and Tracking Technologies above.
- Location Information. You can choose whether to allow the App to collect and use real-time information about your device's location through the device's privacy settings. If you block the use of location information, some parts of the App may be inaccessible or not function properly.
- Third-Party Advertising and Marketing. If you do not want us to share your personal information with unaffiliated third parties for marketing or promotional purposes, you can opt-out by sending us an email stating your request to hello@getmykarma.ca.
- Promotional Offers from the Company. If you have opted in to receive certain emails from us but no longer wish for us to use your email address/contact information to promote our own or third parties' products or services, you can opt-out by sending us an email stating your request to hello@getmykarma.ca. If we have sent you a promotional email, you may unsubscribe by clicking the unsubscribe link we have included in the email. This opt-out does not apply to information provided to the Company as part of a product purchase, warranty registration, product service experience, or other transactions.
We do not control third parties' collection or use of your information to serve behavioural advertising. These third parties may provide you with additional choices about how they use your information or ways to choose not to have your information collected or used in this way. You can opt out of several third party ad servers' and networks' cookies simultaneously by using the Digital Advertising Alliance of Canada Opt-Out Tool. Opting out of a network does not mean you will no longer receive advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.
DATA SECURITY
The security of your personal information is very important to us. We use appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of Users’ personal information. Personal information is maintained on our servers or those of our service providers and is accessible to authorized employees, representatives and agents who require access in connection with their job responsibilities. Any payment transactions will be encrypted. Your online or in-App access to certain of your personal information is protected with a password you select, and you are responsible for keeping it confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the Internet and mobile platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through the App. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any App privacy settings or security measures. If we learn of a breach, we will inform you and the appropriate authorities of the occurrence of the breach in accordance with applicable law.
DATA RETENTION
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 or aggregate your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent. If you withdraw your consent to our processing of your personal information or cancel your account, we will no longer use or disclose your personal information to provide the Services, but we may retain your personal information as necessary for the purposes noted above.
CHILDREN UNDER THE AGE OF 18
Our App is not intended for children under 18 years of age, and no one under age 18 may provide any information to or on the App. We do not knowingly collect personal information from children under 18. If you are under 18, our Terms of Use prohibit you from using this app or registering as a User. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at hello@getmykarma.ca.
ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes by updating your account information in the App. By law you have the right to request access to and to correct the personal information that we hold about you. If you want to access, review, verify, correct, or request deletion of your personal information you may also send us an email at hello@getmykarma.com to request access to, correct, or delete any or all personal information that you have provided to us.
Note that if we cannot delete your personal information except by also deleting your user account, as we cannot make our App or Services available to you without it. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. We may take reasonable steps to verify your identity before granting access or making corrections.
We may be unable to provide you with access to some or all of your personal information in certain circumstances. These include situations where we are legally permitted or required to refuse your request, including situations where applicable privacy legislation creates an applicable exception. Additionally, at the time of your request we may have destroyed, erased or anonymized your personal information in accordance with our record retention obligations and practices. If we cannot provide you with access to some or all of your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
If you are concerned about our response, you may contact our Privacy Officer at the below details:
Neil Hayden – Privacy Officer, MyKarma
Email: privacy@getmykarma.ca
Phone: +1 888 618 6848
COMPLIANCE WITH CASL
By using the MyKarma Platform, you consent to the use of your personal information in order to contact you with commercial electronic messages (as defined in CASL). Such consent shall be considered withdrawn and terminated upon receipt by Karma of an opt-out request by you.
WITHDRAWING YOUR CONSENT
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 privacy@getmykarma.ca.
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 make your decision.
CHANGES TO OUR PRIVACY POLICY
We may update our privacy policy from time to time. It is our policy to post any changes we make to our privacy policy on this. If we make material changes to how we treat our users' personal information, we will post the new privacy policy on this page and notify you by email to the primary email address specified in your account and/or an in-App alert the first time you use the App after we make the change.
We include the date the privacy policy was last revised at the top of the page. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you, and for periodically visiting this privacy policy to check for any changes.
CONTACT INFORMATION AND CHALLENGING COMPLIANCE
We welcome your questions, comments, and requests regarding this privacy policy and our privacy practice, including requests to withdraw your prior consent or challenges to our compliance. To do so, please contact our Privacy Officer at the below details:
Neil Hayden – Privacy Officer, MyKarma
Email: privacy@getmykarma.ca
Phone: +1 888 618 6848
We have procedures in place to receive and respond to complaints or inquiries about our handling of personal information and our compliance with this policy and with applicable privacy laws. To discuss our compliance with this policy, please contact our Privacy & Compliance team using the contact information listed above.