Privacy Policy | Friendlier

A Friendlier Company Inc. Privacy Policy

LAST UPDATED: 2023-06-26

1. OVERVIEW

At A FRIENDLIER COMPANY INC. (“Friendlier”, “we” or “us”), we use our website and other internet-based tools for the following purpose:

We provide reusable packaging products and allow users to claim their container deposit on our website and mobile app. To claim their deposit, consumers have the option to receive their funds as an e-transfer or donate the funds to a charity. We also allow users to find businesses offering Friendlier products, and track their environmental impact.

We are required to collect and retain information about the people and companies that access and use the website (“Users” or “you”). This Policy applies to our privacy practices on all communications between Friendlier and Users, including but not limited to communication via:

i. the Friendlier website (including the website hosted at www.friendlier.ca and any other web domain used by Friendlier to communicate with users now or in the future);

ii. any mobile, computer, or tablet-based application currently offered by Friendlier or developed in the future by Friendlier; and

iii. all other services provided by Friendlier, as described on the Website (Items 1 to 3 are collectively referred to as the "Website").

This Privacy Policy (“Policy”) sets out how we use, protect, collect and preserve information submitted by Users, including User information gathered by our technology. This Policy also explains your rights, including your rights to request information about our data processing, and/or deletion of your data. This Policy should be read in conjunction with any Terms of Use or policies available on the Website.

First, we want you to know that we are committed to protecting your privacy and your personal data and information. We use and disclose your data only to provide the services provided through the Website to you, as explained in this Policy.

By accessing or submitting any information through the Website, you are agreeing to the terms of this Policy. You are prohibited from accessing or using the Website unless you fully understand and agree to this Policy and all Terms of Use available for review on the Website.

If you have any questions about this Policy, please contact us by sending an email with your questions to info@friendlier.ca before accessing or entering any information on the Website.

2. THE INFORMATION WE COLLECT

A. Information You Provide. When you create an account on the Website, we will collect and retain all personal identifying information submitted to us. We will take steps to protect the information submitted to us by Users and we will not disclose any personal identifying information without the consent of Users, unless otherwise set out in this Policy.

Personal identifying information may include but is not necessarily limited to:

Full name, email, e-transfer email, address (optional), current location (optional).

We will not use personal identifying information to contact you for any reason unrelated to your use of the Website or for commercial reasons unrelated to the business of Friendlier. Except with your consent or where required by law, we will not provide personal identifying information to any third party.

B. Your Device. When you use or access the Website, we receive information about the computers, phones, or other web-connected devices and browsers that you use. The device information we receive includes attributes such as the device or browser type, operating system, hardware and software versions, display settings, language, region, geolocation information, currency, and time zone settings, mobile carrier, your IP address, and any device, operating system or advertising identifiers.

C. Your Usage and Transactions. We collect information about how you use the Website, such as the transactions you make or the content you view or engage with. We also retain records of the reusable takeout containers you return or other transactions you submit using the Website, and any interactions with our support team.

D. Cookie Data: When you visit the Website, we use “cookies” and/or similar identifying technology on your device(s) to collect data, including cookie IDs, settings, and usage data. Please refer to our Cookie Statement, as part of Our Supplemental Privacy Policy attached to this Policy, for more information.

3. HOW WE USE YOUR INFORMATION

A. To Provide, Improve and Personalize the Services Provided On the Website. We store and use the data it collects for the following purposes: (i) to provide and support the services provided to you through the Website, including by processing your reusable packaging deposit claims, supporting your reusable packaging deposit claims, and notifying you about deals; (ii) to personalize the services provided to you through the Website, such as by suggesting other products, deciding which products to offer, and administering any applicable rewards programs, discounts, and offers; (iii) to analyze and improve the services provided to you through the Website, such as by marketing to you and measuring the effectiveness of our marketing; (iv) to improve the services provided to you through the Website and develop new services and products (based on usage trends); (v) to ensure the security of the services provided to you through the Website and prevent fraud or other illegal activity, such as by verifying the validity of an attempted reusable packaging deposit claim or payment, which may also include the use of automated decision-making, for example, in relation to assessing fraudulent transactions or suspicious activity; (vi) to comply with applicable accounting, legal and regulatory requirements; and (vii) as otherwise explained to you at the time of the collection of data.

B. To Communicate with You. We also use the data you provide to communicate with you about your reusable packaging deposit claim(s), about deals on products and services that you may be interested in, and/or about other Friendlier products and services that we think you may be interested in. We may communicate with you via in-app push notifications, email, phone, SMS, or other messaging means based on contact information that you provide. You will have the opportunity to decline to receive any marketing communications from Friendlier unrelated to any reusable packaging deposit claim, or support request that you make.

Notwithstanding the above, without restriction, we may use any information you submit through the Website for any purpose we deem appropriate so long as it is anonymous and stripped of any and all personal identifying information.

4. WHEN WE SHARE YOUR INFORMATION

A. To Process Container Deposits. When you request to make a reusable packaging deposit claim, we may share your data to third-party payment processors (such as Interac) and their data-processing partners, and/or to the only as necessary to complete your reusable packaging deposit claim. Third-party payment processors (such as Interac) and their data-processing partners are not controlled by Friendlier, and any data disclosed to them will be subject to that third-party’s privacy policy and security practices. Therefore, we encourage you to review the privacy policies of any applicable third-party payment processors (such as Interac) and their data-processing partners.

B. To Vendors that Help Us Provide the Services. We work with a number of third-party data processing partners who help us provide and improve the services provided to you through the Website. These partners include cloud-hosting services (such as Google Cloud Platform), data analytics (such as Google Analytics) and processing services, communication management (support) services, technology integration partners, survey partners, and payment and fraud-prevention service providers. These third-party processing partners have access to your data only as necessary to perform their functions for Friendlier, and they are not permitted to share or use your data for any other purpose. We cannot control or dictate how any third-party application you use in conjunction with the Website, now or at any point in the future, will treat any personal information you transmit through their servers when using the Website. We advise you to contact these parties directly to review their privacy policies.

C. As Required by Law. We may share information with law enforcement and governmental entities, or in response to legal requests, only when necessary as required by law, or in the good-faith belief that such action is required by law, such as in response to a facially valid judicial, or other governmental entity, order, subpoena or warrant. We may also share information with law enforcement if we have a good-faith belief that such disclosure is necessary to detect, prevent and address fraud, unauthorized use of the services provided to you through the Website, violations of our terms or policies, or other harmful or illegal activity.

D. For Marketing and Analytics Purposes. When you use the services provided to you through the Website, we may share your device advertising identifier (e.g., IDFA on iOS and AdID on Android) or cookie information, and information about actions you take in the app, if you have enabled these features in your device settings, with third parties for the purpose of analyzing the effectiveness of our marketing activities and/or future marketing activities. You can disable, opt-out, and prevent the sharing of this information in your device or browser settings without impacting your ability to use the services provided to you through the Website. We will accept your decision to disable sharing of your device advertising identifier as your signal of an election to opt-out of sharing and limit the use and processing of your personal data, and will abide by that decision in a frictionless manner. If you permit the sharing of such information, our third-party partners may combine information they receive from us with information about you obtained from other sources.

5. YOUR RIGHTS TO YOUR PERSONAL INFORMATION, TO OPT-OUT OF SHARING AND TO LIMIT PROCESSING

We provide all Users, regardless of your country of residency, with rights to access (receive a copy of), rectify, and/or delete your personal information. You may also object, or withdraw consent, to future sharing or processing of your data by Friendlier. You may make any such requests to Friendlier by utilizing an opt-out button within the mobile app, or by emailing us at info@friendlier.ca and subsequently verifying your identity as requested by Friendlier. Please note that the linked opt-out form will not be effective if accessed from a web browser outside the mobile app. Absent exceptional circumstances, there is no fee for such requests and we will respond within thirty (30) days, or otherwise as required by law. Please note that certain services provided to you through the Website that require data processing may no longer be available to you following a request for data deletion or cessation of processing, and a withdrawal of consent to processing will not prevent the Friendlier from continuing to process data where Friendlier relies on a legal basis other than consent. If you are a resident of Canada, you may have additional rights under the Personal Information Protection and Electronic Documents Act (PIPEDA). These rights are explained in our Supplemental Privacy Policy following this Policy.

If you have not accessed your account for a total of 3 years, we may terminate your account, without notice, along with any personal information retained by us.

When deleting your information, whether by request or due to inactivity, we will use standard electronic means to remove your personal information from our files.

We will also retain any and all information that we are required to retain under any applicable laws for the full duration of time required under those laws.

6. INTERNATIONAL DATA TRANSFER

We share information globally to the external processing partners and third-party suppliers mentioned above. Your information may, for example, be transferred or transmitted to, or stored and processed by, our partner group entities and/or third-party data processors located in the United States, Canada, or other countries outside of where you live, as necessary for the purposes as described in this Policy and to provide the services provided to you through our Website. The laws in the countries in which your data is processed may differ from the laws in your home country. In order to protect your data during processing in any country, Friendlier obtains your consent for these data transfers to the United States and other countries. By using the services provided to you through our Website, you consent to these international data transfers.

7. KEEPING YOUR DATA SECURE

We will store your information in electronic format on industry-standard servers that we have selected. Except where required to do so by law, we will not store your personal information in any physical or paper-based format.

The servers we select to store information engage security software and generally accepted standards to protect personal information. The software used by these servers is intended to prevent unauthorized access or improper use.

However, no security system is perfect and there is always a risk of unauthorized parties accessing your personal information. Therefore, we make no guarantees or representations as to the technical or legal compliance of the servers we use. We cannot guarantee the complete protection and security of your personal information.

Our servers may be located outside of Canada, and thus are potentially subject to the privacy and security laws in force in other countries. If you have concerns about your personal information being stored electronically in foreign jurisdictions, please contact us before proceeding to use the Website.

8. SECURITY BREACHES

In the event the personal information of a User is disclosed as the result of any breach of security of the Website or its servers, regardless of who is at fault, we will take steps to advise all known affected Users within 3 days of learning of the breach.

9. USE OF WEBSITE BY MINORS

The Website is not intended to be accessed by persons under the age of 18. Friendlier does not engage in any marketing efforts aimed at children or minors. Persons under the age of 18 are prohibited from using the Website in any manner or providing any information to Friendlier. In the event Friendlier is provided with any information, including personal identifying information, relating to a minor, that information will be immediately deleted without notice.

10. ADDITIONAL DISCLOSURE OF PERSONAL INFORMATION

In addition to the reasons described above in Section 4, in certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

We may disclose your personal information to third parties:

i) In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.

ii) If Friendlier or its assets are acquired by a third party, in which case personal data about Users may be one of the transferred assets.

iii) If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms of Use; or to protect the rights, property, or safety of Friendlier, our Users, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

11. USER REFERRAL SERVICE

You can choose to provide us with the names and email addresses of individuals or organizations that you feel would be interested in learning more about our products and services. When you choose to engage this service, we may send a preliminary email to each address provided to us, inviting the contact to visit our website. We continue to store the contact details in order to track the success of our referral service.

12. AMENDING THIS POLICY

This Policy may be updated and amended from time to time. We reserve the right to change this Policy at any time at our discretion, and any amended Policy is effective upon posting to the Website. We will make efforts to communicate any changes to this Policy we deem material, in our sole discretion or where required by law, via email or notifications on the Website and give you the opportunity to review the amended Policy before you choose to continue using the services provided through the Website. It is your responsibility to monitor the Website regularly for changes to this Policy. You agree that if you do not agree to any such change, you shall immediately stop using the Website and the services provided to you through the Website. Your continued use of the Website will be deemed immediate and unconditional acceptance of any amended Policy, whether or not we deemed the amendments to be material.

13. CONTACT US

We encourage you to send us questions and inquiries on this Policy, or your personal data, or to make an access, deletion, or correction request, or to exercise any other applicable rights and the steps we take to keep your personal information secure. Please send us an email: info@friendlier.ca, or by mail to:

42 Carden Street,

Guelph, Ontario

N1H 3A2

We will respond to all inquiries on the Policy within 7 days.

Supplemental Privacy Policy for Residents of Canada

This Supplemental Privacy Policy (“Policy”) supplements Friendlier’s Privacy Policy and explains: (1) how Friendlier collects and uses Personal Information with specific reference to the requirements of the Personal Information Protection and Electronic Documents Act (PIPEDA) and; (2) your rights under each of this Act.

1. Definition of "Personal Information" Friendlier uses the Personal Information that it collects from you in accordance with our Privacy Policy, and otherwise in accordance with PIPEDA. Friendlier does not sell your Personal Information. The term “Personal Information,” for purposes of each of the above-referenced Laws, means:

Law/Regulation

Meaning of "Personal Information"

PIPEDA

Information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

2. Data Controllers The following Friendlier entity acts as the Controller for data collected from you in the following jurisdiction:

Jurisdiction

Data Controller

Canada

42 Carden Street,

Guelph, Ontario

N1H 3A2

3. Categories of Information Collected, Used, Shared. The table below summarizes the categories of Personal Information Friendlier may have collected about you over the past 12 months, depending on how you use our Website, as well as how we use it and with whom we may have shared it:

Categories of Personal Information Collected

Examples of How Personal Information is Used

Categories of Persons to Whom Personal Information is Shared

Identifiers (e.g., real name, alias, postal address, internet protocol address, email address, or other similar identifiers).

Providing, personalizing, and improving the services provided to you through the Website.

Third-party payment processing service suppliers, and their respective data-processing partners.

Commercial information, including records of reusable packaging deposit claims or consuming histories or tendencies.

Facilitating reusable packaging deposit claims and payment transactions, and offering and providing products and services.

Friendlier entities and their respective data-processing providers and service vendors.

Internet or other electronic network activity information, including your interactions with the Website or applications.

Ensuring security of the services provided to you through the Website.

Law enforcement or other third parties in connection with legal requests.

Communicating with you.

New owners, in the event of a change of ownership or control of all or part of Friendlier or the services provided to you through the Website.

Performing Friendlier business analytics.

Friendlier entities.

4. Sources of Information Friendlier receives Personal Information from you, including information that you provide or from your usage of the services provided to you through the Website, and from your device(s). This collection of data is explained in our Privacy Policy. The categories of sources from which we’ve collected or received Personal Information include:

Source

Information Collected

You

To make reusable packaging deposit claims using the Website or to communicate to Friendlier for other purposes, you may be required to provide personal information including, for example, your name, phone number, email, date of birth, gender, and payment information. Friendlier collects information about the reusable packaging deposit claims and transactions that you make, and the content, pages, and food services that you access and interact with, and how you use the services provided to you through the Website, including products that Friendlier offers. Friendlier collects information about your communications to us, such as for purposes of customer support.

Your Device(s)

Friendlier collects information from and about the computers, phones, browsers, and other web-connected devices you use to access the services provided to you through the Website.

5. Lawful Bases for Processing Friendlier collects, uses, processes and discloses personal information based on: (i) the need to process data to carry out Friendlier’s contractual obligations to you and/or Friendlier’s legal obligations; (ii) your consent, for the uses and purposes set forth in Friendlier’s Privacy Policy and/or as explained at the time of the data collection; and/or (iii) based on Friendlier’s legitimate interest in delivering, improving, and providing the services provided to you through the Website, consistent with the purposes for which you provided the data to Friendlier, where such interest is not overridden by your rights. Friendlier will store personal information for an indefinite period of time as necessary to continue to provide the services provided to you through the Website.

If Friendlier collects and uses your personal information in reliance on its legitimate interests (or the legitimate interests of any third-party), this interest will typically be to operate or improve the Friendlier platform and communicate with you as necessary to provide services to you, for security verification purposes when you contact Friendlier, to respond to your queries, undertaking marketing, or for the purposes of potentially detecting or preventing illegal activities.

Friendlier may in some cases use automated decision-making, for example, in relation to assessing fraudulent transactions or suspicious activity on the Website. As part of this processing, automated decisions may be made by putting your personal information into a system and the decision is calculated using automatic processes. If you pose a fraud risk, this may affect your ability to make reusable packaging deposit claims on the Website. You may have rights in relation to automated decision making, including the ability to request a manual decision-making process instead or contest a decision based solely on automated processing. If you want to know more about your data protection rights, please contact Friendlier by emailing: info@friendlier.ca.

6. Consumer Rights - Canada Residents If you are a resident of Canada, you have the right under PIPEDA to request from Friendlier:

information about the existence, use, and disclosure of your personal information;
a copy of such information; and
an account of the use that has been made or is being made of this information and an account of the third parties to which it has been disclosed.

7. Exercising Consumer Rights You may exercise your rights and make requests for information or deletion by emailing us as: info@friendlier.ca. Please note that to protect your information and the integrity of our services and products, we may need to verify your identity before processing your request. In some cases we may need to collect additional information to verify your identity, such as a government issued ID.

8. Cookie Statement “Cookies” are small pieces of text sent as files to your computer or mobile device when you visit most websites. When you use the Website, cookies may be delivered by Friendlier (“first-party” cookies) or delivered by a third-party provider (“third-party” cookies). Cookies are either session cookies or persistent cookies. Session cookies enable Friendlier to recognize and link the actions you take during a single browsing session. Persistent cookies enable Friendlier to recognize you as an existing user, and these cookies are stored on your system or device until they expire, or until you delete them. Friendlier also may use other technologies similar to Cookies, including (and all are referred to as “Cookies”):

Pixels are small objects embedded into a web page that are not visible to the user. We use pixels to deliver cookies to your computer, facilitate the log-in process, monitor the activity on our sites, and deliver online advertising.
Tags are small pieces of HTML code that tell your browser to request certain content generated by an ad server. We use tags to show you relevant advertising and promotions.
Scripts are pieces of JavaScript code that launch automatically when certain webpages load, to determine whether users view associated advertisements.
Local Storage Objects, such as HTML 5, are used to store content and preferences. Third-parties with whom we partner to provide certain features on our site to display advertising based upon your web browsing activity use Local Storage Objects to collect and store information.

Types of Information Collected Using Cookies. As explained in Friendlier’s Privacy Policy, the types of information that we collect through cookies include: IP address; Device ID; Viewed pages; Browser type; Browsing information; Operating system; Internet Service Provider; Whether you have responded to, or interacted with, an advertisement; Referring or referred links or URLs; and Features used and activities engaged in on our sites and in our apps.

How we use Data Collected Using Cookies. Friendlier uses Cookies on the Friendlier Website for a number of reasons, including to: (i) Help us improve your experience when visiting our applications and websites; (ii) Fulfill reusable packaging deposit claims and ensure our applications and websites perform as intended; (iii) Remember your preferences, such as language, region, or currency; (iv) Provide you with relevant advertising and analyze performance of the ads; (v) Identify errors on our sites; (vi) Help with data protection and potentially detect and investigate malicious or fraudulent activity; (vii) Help us understand traffic to our site, including time and date of the visit, time and date of the last visit, and other information; and (viii) Analyze how well our sites are performing.

Types and Functions of Cookies.

Essential Cookies. Certain cookies are required or “essential” for our sites to function as intended. Essential cookies are necessary for you to navigate our site and use certain features like logging in to your account and managing your claims. These cookies are also used to remember security settings that allow access to particular content. Lastly, we use essential cookies to collect information on which web pages visitors go to most, so we can improve our online services. You are not able to opt out of essential cookies.

Functional Cookies. We want to make sure when you visit our site, your preferences (such as your preferred language), settings, and previous searches are remembered. Functional cookies enhance your experience on any Friendlier site.

Analytics Cookies. We use analytics cookies to understand our site’s performance and how it is used, including the number of visitors, how long you stay on the site, and which parts of the site you visit. We can see details about how visitors interact with the sites, like the number of clicks visitors made on a given page, their mouse movements and scrolling activity, the search words visitors used, and the text visitors enter into various fields. We also use Analytics Cookies to test different designs and features for our site, determine effectiveness of our advertising, and to improve our services, including your experience on our site. For analytics, our third-party service providers may use cookies to perform their services and may combine the information that they collect about you on our sites with other information that they have collected. This Cookie Statement does not cover such third-parties’ use of your information.

Advertising Cookies. Friendlier and our third-party advertising partners may use advertising cookies to show you advertisements both on and off our applications and websites that are based on your interests. We may allow third-parties to collect information about your online activities through cookies to perform their services and may combine the information that they collect about you on our sites with other information that they have collected. These third-parties include business partners who collect information when you view or interact with one of (1) their advertisements on our sites or (2) our advertising on their sites and advertising networks, which collect information about your interests when you view or interact with one of the advertisements or tracking mechanisms they place on many different sites on the Internet. Our partners may make assumptions about your interests, characteristics, or preferences and add you to groups based on those assumptions in order to show you tailored advertisements. Friendlier does not have access to the cookies these third-parties may use to collect information about your interests, and the information practices of these third-parties are not covered by this Cookie Statement or our above Privacy Policy.

Manage your Cookies. You can set or amend your web browser controls to accept or refuse cookies whenever you like, but please remember if you do choose to reject cookies, your access to some of the functionality and areas of our site may be restricted.

Do-Not-Track Signals and Similar Mechanisms. Some web browsers may transmit "do-not-track" or Global Privacy Control (GPC) signals to sites with which the browser communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether web users intend for these signals to be transmitted, or whether users are even aware of them. Friendlier is evaluating the use of opt out signals received by its website. Friendlier currently does take action to such signals within the Friendlier mobile app by recognizing a user's decision to block the sharing of a device IDFA (iOS) and/or AdID (Android) as a signal of the user's intent to opt-out of the sharing of data for certain marketing purposes and to limit the processing of data as set forth above in this Privacy Policy.

Effective Date of this updated Privacy Policy: July 3, 2023