Introduction
Flynn Canada Ltd. (“Flynn”) is committed to controlling the collection, use and disclosure of personal information providers by users of its mobile applications. This Privacy Policy is intended to establish responsible and transparent practices for the management of personal information and to satisfy the requirement and rules established by the Personal Information Protection and Electronic Documents Act (PIPEDA) as well as other provincial privacy laws and standards which may apply.
Application
This Privacy Policy applies to the personal information that Flynn collects, uses or discloses in respect of users of the Flynn Coaching mobile application.
Definition of Personal Information
When used in this Privacy Policy, “personal information” means any information about an identifiable individual. This may include, for example, information relating to your account with us, including your identity, and may also include other types of more technical information such as subscribers/users IP addresses, user IDs, and metadata, but only when this information can identify you as an individual.
Collection of Personal Information
When you sign up to use the Flynn Coaching mobile application we collect and retain the personal information you provide, including your:
- Name;
- Email address;
- Employee ID; and
- Date of birth.
When you access the Flynn Coaching mobile application, we also automatically receive your computer’s internet protocol (IP) address, and information about your device and operating system.
Flynn collects and uses your personal information primarily for the purpose of providing you with the products and services you have requested from us, including the use of the Flynn Coaching mobile application.
Your personal information is used to communicate with you about your account and to provide you with information about Flynn’s products and services, including emails about the Flynn Coaching mobile application, new Flynn mobile applications and other related updates.
Your personal information will be retained only as long as it remains necessary or relevant for the identified purposes or as required by law.
Consent
Providing Flynn with the personal information required to complete your registration in the Flynn Coaching mobile application, constitutes your implied consent to our collection, use, retention and disclosure of such personal information and using it for the purposes set out herein.
When Flynn proposes to use personal information that has been collected for a purpose not previously identified, it will identify the new purpose before using such personal information. Unless the new purpose is required by law, or consent is otherwise not required pursuant to privacy legislation, your consent will be obtained before your personal information is used for the new purpose.
If you wish to withdraw your consent to certain collection, use, retention or disclosure of your personal information, you may do so at any time by contacting us by email at [email protected] or by mail at: Flynn Canada Ltd., 6435 Northwest Drive, Mississauga, ON, Canada L4V 1K2.
Please note that if you refuse or withdraw your consent, we will not be able to provide you with product or services, including the Flynn Coaching mobile application.
Disclosure
We may disclose your personal information if we are required to do so by law. In particular, we may disclose your personal information:
- To third parties who are acting on our behalf as our agents, suppliers or service providers who are subject to confidentiality requirements;
- To internal or external legal counsel and auditors;
- To Flynn’s management personnel;
- To third parties retained by Flynn for the development, enhancement or marketing of Flynn’s products or services;
- To a third party or parties, where you have consented to such disclosure;
- To prospective parties in the context of a transactional due diligence review; and
- Where disclosure is required by law.
Hosting
Our mobile application is hosted on Microsoft Azure. Microsoft Azure provides us with the online storage and data processing that allows us to make the Flynn Coaching mobile application available to you. This means that your personal data is stored in Microsoft Azure.
Third-Party Services
In general, third parties acting on our behalf as agents, suppliers or service providers will only be provided with your information to the extent necessary to allow them to perform the services they provide to us.
Except as required or permitted by law, when disclosure is made to a third party, your consent shall be obtained and reasonable steps shall be taken to ensure that any such third party has personal information privacy procedures and policies in place that are at least comparable to those implemented by Flynn. Such third party service providers are provided only with such information as is necessary in the circumstances. Personal information provided to third parties may be used only for the purpose stipulated and is subject to strict terms of confidentiality.
Once you leave our Flynn Coaching mobile application or are redirected to a third-party website or application, you are no longer governed by this Privacy Policy or our website’s Terms of Service. When you click on links in the Flynn Coaching mobile application, you may be directed away from our mobile application. We are not responsible for the privacy practices of other websites or mobile applications and encourage you to the privacy policy and terms of use relating to each external website or mobile application.
Unless authorized by you, Flynn will not sell, lease or trade your personal information with third parties.
Personal Information Outside of Canada
In some cases, the third parties mentioned above may be located in or have facilities that are located outside of Canada. If you elect to proceed with a transaction that involves the services of a third party service provider, your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.
For example, if you are located in Canada and your user profile information is stored and processed in the United States, then your personal information used in your profile may be subject to disclosure under United States legislation, including the Patriot Act.
Security
We implement security safeguards and follow industry best practices to protect your personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification.
The nature of the safeguards will vary depending upon: the sensitivity of the information that has been collected; the amount, distribution and format of this information; and the method of storage.
Although no method of transmission over the Internet or electronic storage is 100% secure, we implement generally accepted industry standards.
Age of Consent
By using this site, you represent that you are at least the age of majority in your state or province of residence, or that you are the age of majority in your state or province of residence and you have given us your consent to allow any of your minor dependents to use this site.
Changes to this Privacy Policy
We reserve the right to modify this Privacy Policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon the modification of this Privacy Policy. You may determine when this Privacy Policy was last updated by referring to the date found at the bottom of this Privacy Policy.
Questions and Contract Information
If you would like to: access, correct, amend or delete any personal information you have provided to us, register a complaint, or simply want more information regarding the Flynn Coaching mobile application, please contact us by email at [email protected] or by mail at Flynn Canada Ltd., 6435 Northwest Drive, Mississauga, ON, Canada L4V 1K2.
Last revised August 8, 2017.