Introduction

TriSpects Inc. ("TriSpects", "we", "us", and "our") operates in-house mobile applications (the "Application"). To facilitate services, we utilize some of the personal information that you provide to us. We also provide you with the ability to communicate directly with other users through the Application.

This Privacy Policy describes the personal information that we collect from or about you, on or through the Application. By accessing or using the Application, you confirm your acceptance of this Privacy Policy. You agree to be bound by its terms. You can decline your consent; however, if you choose to do so, we may not be able to provide you with the services that are available through the Application.

Please note that we may share the personal information that you provide to us through the Application with other users. This Privacy Policy does not apply to the personal information you provide directly to other users.

• What is personal information

For the purposes of this Privacy Policy, personal information is any information about an identifiable individual

• This Privacy Policy is effective for Canada

We are subject to the Personal Information Protection and Electronic Documents Act (Canada) and applicable Canadian provincial privacy legislation. Privacy laws vary by jurisdiction. You acknowledge and agree that access to the Application and the services that are available through the Application is provided via the Internet and that your information, including personal information, may be transferred across national borders and stored or processed under the terms and conditions of this Privacy Policy. As a result, the rights and obligations contained in this Privacy Policy may not be consistent with privacy requirements for all jurisdictions. If you are visiting our Application and are not a resident of or located in Canada, you should note that by providing your personal information to us, you are: (i) permitting the collection, use, disclosure, transfer and other processing of your personal information in Canada which may not have the same personal information protection laws as the jurisdiction in which you reside; and (ii) permitting the use of your personal information under this Privacy Policy and the laws of Canada.

• Links to third party websites

Our Application may contain links to other websites and digital platforms that may be subject to less stringent privacy standards. These links are provided for your convenience only, and you assume all risk for clicking these links to other websites and digital platforms. We cannot and do not assume any responsibility for the third parties' privacy practices, policies, or actions that operate these websites. We are not responsible for how such third parties collect, use or disclose your personal information. You should review the privacy policies of these websites before providing them with personal information.

• Changes to this Privacy Policy

We may make changes to this Privacy Policy from time to time to reflect changes in its legal or regulatory obligations or how we deal with your personal information. We will post any revised version of this Privacy Policy on our Application. If we make any material changes, we will notify you as required by law but encourage you to check back often for updates. Your continued use of the Application after any update or amendment to this Privacy Policy means that you consent to collecting, using, and disclosing your personal information as described in the updated Privacy Policy.

• The personal information that we collect

We may collect and maintain different types of personal information regarding the individuals with whom we interact. This personal information may include, but is not limited to:

• contact and identification information, such as your name, mail address, telephone number, and e-mail address;
• demographic information, such as your date of birth;
• location information;
• any personal information that is contained in or on any accounts that you have with third parties that you use in connection with your access to and use of the Application (e.g., using your Facebook, Google, LinkedIn, or Apple Account to sign-up to register with us). This information includes your first name, last name, e-mail address and telephone number;
• any personal information, including personal health information and other medical information, that you include on any screening forms that you complete in connection with your use of the Application, such as COVID-19 pre-screening forms as are required under applicable laws; and
• any additional personal information you provide when using the Application and our services, including any personal information included in any of your User Content (as defined in the Terms).

By submitting User Content that includes personal information on or through the Application, you choose to share your personal information with other users and the businesses you communicate with. Please exercise caution in sharing your information and make sure that the information you share is information that you are comfortable being publicly viewable since neither you nor we can control what others do with your information once you share it publicly on or through the Application.

As a general rule, we collect personal information directly from you. In most other circumstances, where a third party holds the personal information we collect about you, we will take reasonable steps to ensure that such a third party has obtained your permission to provide us with this information. Such permission may be given directly by you or implied by your actions. From time to time, we may utilize the services of third parties. We may also receive personal information collected by those third parties in the performance of their services for us or otherwise. Where this is the case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us. 

• Other information that we collect when you use the Application

In addition to the personal information you may provide to us as described above, we automatically collect certain device and statistical data to make our Application work better for you. For example, we may collect the IP address, network connection, the device domain used to access our Application, your device settings, crash data, other unique device identifiers, and your location.

We may use cookies and other technologies that are similar to cookies ("Cookies"). A cookie is a small file of letters and numbers that we may set on your device to store and sometimes track information about you. Cookies and similar technologies we use are designed for "analytics." This allows us to distinguish you from other users of the Application. This helps us to provide you with a good experience when you use the Application and allows us to improve our Application.

First-party Cookies are Cookies set by the website that you are visiting. Only that website can read them. In addition, a website might potentially use external services, which also set their own cookies, known as third-party cookies. Persistent Cookies are Cookies saved on your computer that are not deleted automatically when you quit your browser, unlike a session cookie, which is deleted when you quit your browser.

We use the following Cookies:

• Strictly necessary Cookies: Cookies that are necessary for the operation of the Application. For example, cookies that enable the Application to remember information that has been previously searched; and
• Analytical Cookies: Cookies that allow you to count the number of visitors and see and track when visitors are logging into the Application when they are using it.
• The reasons we collect personal information

We only collect information from you that is necessary to provide you with the services available through our Application, enabling us to manage, maintain, and develop our operations. For example, we collect information in order to:

• Establish, maintain and manage our relationship with you, including by contacting you, so that we may provide you with any services or communications that you have requested or purchased access to, on, or through our Application;
• verify your identity and eligibility to access and use the Application and our services, receive our communications and otherwise interact with us and on and through our Application;
• to verify and confirm that a transaction has been completed before we provide you with access to and use of our Application, our services, and communications;
• allow you to use and interact with the Application and its various functions, including by providing User Content (as defined in the Terms);
• be able to comply with your requests (e.g., if you prefer to be contacted at a specific e-mail address and advise us of your preference, we will use this information to contact you at that number);
• understand your preferences and tailor communications and services to you, and send you information about our partners and us;
• protect our partners and us against error, fraud, theft and damage to our Application, assets or other properties;
• conduct analysis, research and development, and evaluations to understand usage and trends to improve our Application, services, communications and operations;
• enable us to comply with applicable laws or regulatory processes; and
• any other reasonable purpose to which you consent.

By consenting to our collection, use and disclosure of your personal information through our Application, you allow us to fulfill the purposes for which we collect your personal information.

How we use personal information

We may use your personal information:

• as permitted or required by applicable law or regulatory requirements;
• for the purposes described in this Privacy Policy; and
• for any additional purposes, we have obtained your consent to use your personal information.

We may use your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.

We will collect your consent prior to sending you any commercial electronic messages unless an exception under Canada's Anti-Spam Legislation (CASL) applies. When you do register with us or give us personal information, you may have an opportunity at the time we collect your information to opt-in to receiving e-mails from third parties and us.

You can also opt out of receiving marketing communications through the unsubscribe links that are included in our commercial electronic messages. 

Affiliates, employees, and contractors

We may disclose your personal information to our affiliates and our employees, contractors, consultants, service providers, and other parties who require such information to assist us with managing our relationship with you, including third parties that provide services to us or on our behalf. For example, we may share your personal information with TriSpects Inc. and its subcontractors, which assist us with the hosting, operating, and maintenance of the Application.

Business transactions

Personal information may be disclosed or transferred to another party during the course of or upon completion of, a change in ownership of, or the grant of a security interest in, all or a part of TriSpects or its affiliates through, for example, an asset or share sale, or some other form of the business combination, merger or joint venture, provided that such party is bound by appropriate agreements or obligations and required to use or disclose your personal information in a manner consistent with the use and disclosure provisions of this Privacy Policy unless you consent otherwise.

Other disclosures

Your personal information may be disclosed:

• as permitted or required by applicable law or regulatory requirements;
• to comply with valid legal processes such as search warrants, subpoenas, or court orders;
• to respond to any claims, to prevent, investigate, identify persons or organizations potentially involved, or take any action regarding suspected fraud, violations of our Terms, or activity that appears to be illegal or we believe may expose us to legal liability;
• during situations that we believe to be emergencies involving potential threats to the physical safety of any information that in any way relates to that threat; and
• for any additional purposes for which we have obtained your consent to disclose your personal information.

Since we may share your personal information with third parties, as described in this Privacy Policy, your personal information may be collected, used, processed, stored, or disclosed outside your residence jurisdiction, including in the United States. As such, your personal information may potentially be accessible to law enforcement and national security authorities of another jurisdiction. For example, we share user identification information, such as your name and e-mail, with Stripe for payment processing purposes. If you would like further information about our policies and practices regarding the third parties (including our contractors) with whom we disclose your personal information and how these third parties collect, use, disclose and store personal information, please contact our Privacy Officer using the contact details below. 

How long do we retain your personal information?

We don't keep your personal information forever. We keep your personal information as long as is reasonably necessary for us to complete our dealings with you, or as may be required by law, whichever is longer.

How do we obtain your consent and how can you withdraw it?

It is important to us that we collect, use or disclose your personal information where we have your consent to do so. Depending on the sensitivity of the personal information, your consent may be implied, deemed (using an opt-out mechanism), or expressed. We may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required to do so by applicable law or regulatory requirements.

Typically, we will seek your consent at the time that we collect your personal information. In certain circumstances, your consent may be obtained after collection but before our use or disclosure of your personal information. If we plan to use or disclose your personal information for a purpose not previously identified (either in this Privacy Policy or separately), we will endeavor to advise you of that purpose before such use or disclosure.

You may change or withdraw your consent at any time, subject to legal or contractual obligations and reasonable notice, by contacting our Privacy Officer using the contact information set out below. All communications with respect to such withdrawal or variation of consent should be in writing and addressed to our Privacy Officer.

Unless you advise us otherwise, you agree that, through your access and use of the Application, you have consented to the collection, use, and disclosure of your personal information as explained in this Privacy Policy.

Protecting your personal information

TriSpects will endeavour to maintain commercially reasonable physical, technical, and procedural safeguards that are appropriate based on the sensitivity of the personal information in question. These safeguards are designed to prevent your personal information from loss and unauthorized access, collection, use, disclosure, copying, modification, disposal, or destruction. Please note that by submitting User Content (as defined in the Terms) that includes personal information on or through the Application, you are choosing to share your personal information with other users (i.e., the public).

Accessing your personal information

You can ask to access the personal information that we have received from or possess about you. If you want to review, verify, delete or correct your personal information, please contact our Privacy Officer.

When requesting access to your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information that we hold about you. If you require assistance in preparing your request, please contact our Privacy Officer.

Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed, erased, or made anonymous in accordance with our record retention obligations and practices. In the event that we cannot provide you with access to your personal information, we will endeavour to inform you of the reasons why subject to any legal or regulatory restrictions.

Updating your personal information

It is important that the information contained in our records is both accurate and current. If your personal information happens to change during the course of our relationship, please keep us informed of such changes. You change or update the information we have about you through the Application.

In some circumstances, we may not agree with your request to change your personal information and will instead append an alternative text to the record in question.

Interpretation of this Privacy Policy

This Privacy Policy includes examples but is not intended to be restricted in its Application to such examples; therefore, where the word "including" is used, it shall mean "including without limitation".

This Privacy Policy does not create or confer upon any individual any rights or impose upon TriSpects any rights or obligations outside of, or in addition to, any rights or obligations imposed by Canada's federal and provincial privacy laws, as applicable. Should there be, in a specific case, any inconsistency between this Privacy Policy and Canada's federal and provincial privacy laws, as applicable, this Privacy Policy shall be interpreted, in respect of that case, to give effect to, and comply with, such privacy laws.

Contact us

If you have any questions about this Privacy Policy or concerns about how we manage your personal information, please get in touch with our Privacy Officer by e-mail. We will endeavour to answer your questions and advise you of any steps taken to address the issues raised by you. If you are dissatisfied with our response, you may be entitled to make a written submission to the Privacy Commissioner in your jurisdiction. We have appointed a Privacy Officer to oversee compliance with this Privacy Policy. The contact information for our Privacy Officer is as follows:

• by e-mail to: info@TriSpects.com
• by mail to: 6660 Kennedy Road, Suite 201 Mississauga, ON L5T 2M9, Canada