Last updated: September 25, 2012.
What Information We Collect
We collect two types of Personal Information: (i) personally identifiable information (“PII”), which constitutes any information that can identify an individual directly or through other reasonably available means and is otherwise referred to herein as “personal information”, but does not include information deemed not to be personal information in accordance with applicable law; and (ii) non-personally identifiable information (“Non-PII”), which is also referred to as aggregate and anonymous data, or is information that would not, in and of itself, identify you. Please note that what one may initially consider to be Non-PII may, in some contexts, such as in respect of small geographic locations or communities, result in such information being attributable to you or allowing you to be identified because of the context. Please consider this when providing information.
What Information We Ask You For
When you register with the Services, you will be asked to provide us with certain PII about yourself such as your name, email address and password. In addition, if you wish to provide such information, you will be asked to provide your date of birth and gender.
In the future, we may permit you to import your account information from a third party API to make the registration process easier. In such circumstances, we will collect information from such third party and may ask that you provide additional information in the event we are not able to access required information from the API.
What Information We Automatically Gather
Some Non-PII is automatically collected when you use or visit the Services. We collect and store information related to your use of the Services, such as your IP Address, and information pertaining to your mobile device, network, protocols and software and the date and time of your visit. The Non-PII we automatically collect is used to help us provide a more relevant and useful site experience to you. This information is also used in the aggregate to perform statistical analyses of user behavior and characteristics in order to measure interest in and use of the various areas of the Services.
The Non-PII is typically collected through “cookies”. A cookie is a small piece of information that can be stored by your web browser on your hard drive. We use “persistent cookies” to store your Credentials for future logins to the Services. When you revisit the Services, our server will recognize the cookie and collect the aforementioned information. Additionally cookies are used to help us analyze the Services usage more accurately by keeping tracks of User interaction. Our cookies do not collect your name, email address, contact information or other PII. If you are uncomfortable with our practice of using cookies, you can disable all cookies through your browser settings; however, if you disable cookies, you may not be able to use certain aspects of the Services.
What Other Information May Be Collected
Party Services. In the future, we may allow you to access third party services, such as Facebook and Twitter, to share your Public Profile with those services, and import information about who you are connected with on those other services so you can connect with them on the Services. Some of those third party services may also provide us with information from your accounts. You can always opt out of sharing with such third party services on your account page.
Feedback. You should feel free to give us feedback, register a complaint, or ask questions about the Services. We may store your communications, including any Personal Information you include in them, so that we can effectively respond to you.
How We Use Your Information
Our primary objective in collecting your information is to provide services that are of the greatest interest and use to you. In addition to those uses mentioned above, we use the PII collected for the following purposes: (i) for registration and sign-in; (ii) to manage your account; (iii) to communicate with you; (iv) to provide relevant information to Locations for purposes of providing the purchased Products; (v) to measure interest in and improve our Services; (vi) to provide you with information and offers from us or third parties that we believe you may find useful or interesting, including marketing or promotional materials, advertisements, coupons and other information on services and products offered by us or third parties; (vii) to resolve disputes troubleshoot problems; and (viii) to monitor the Services and to enforce the TOS. In addition, the Personal Information allows us to develop and customize the Services and to better understand what products and services you would like. The Personal Information may also be used to send you e-mails that we believe may be of interest to you, such as our newsletters. You may opt out of receiving any such e-mails by unsubscribing; simply follow the unsubscribing instructions.
In addition to the uses mentioned above, we use the Non-PII collection for the following purposes: (i) to monitor and analyze use of the Services and for the technical administration of the Services; (ii) to increase functionality and user-friendliness of the Services; (iii) to better tailor the Services to your needs; (iv) to generate and derive useful data and information concerning the interests, characteristics and use behavior of our users, and to verify that users of the Services meet the criteria required to process their requests.
How We Share Your Information
We may share you information with the following parties and/or for the following purposes. Please note that we will never share your username or password for your Online Accounts (as such term is defined in the TOU) except to affiliates and trusted third party services providers (as described below) only where necessary to provide the Services:
Affiliates. We may share much of our data, including your PII, with our parent, subsidiary and other affiliated companies (each a "Related Entity") that are committed to serving your online needs and providing related services.
Trusted Third Party Service Providers. We may use third parties to provide technical support and perform tracking and reporting functions, conduct quality assurance testing, and provide other services in connection with the Services. We may share information about you with them so that they can perform the services they are required to perform.
Other Third Parties. We may share information with other parties whom you ask us to send Personal Information, whether explicitly or by using the Services.
Third Party Advertising. Third parties may serve some of the ads on the Services. We do not provide individualized Personal Information to them, but they may have access to information that they obtain through cookies or that you share with them yourself. Note that we do not rent, sell or trade personal information with third parties for their direct marketing purposes. In addition, we may use your information to enable our marketers and advertisers to understand who are our users, i.e. the information collected will be compiled to create general profiles of users, demographic information and interests.
Aggregate Information. We may share non-PII in the aggregate to third parties relating to user behavior in connection with actual or prospective business relationship with those third parties, such as advertisers and content distributors. For example, we may disclose the number of users that have been exposed to, or clicked on, links.
How We Protect Your Personal Information
We understand how important protecting your privacy is, and we are committed to safeguarding the information you provide to us. And while we cannot guarantee absolute security, we have implemented specific security procedures to protect the storage and disclosure of your information. Access to your information is restricted to select employees or representatives.
How You Can Correct Your Information
To update your Personal Information, please log in to your account and correct the information that needs to be updated.
How Long We Keep Information
We keep the Personal Information you have given us for at least as long as you maintain as maintain your account. Keep in mind, however, that even if you delete your account, we may retain your Personal Information in conformance with our data retention policy, under which we may reasonably retain such information to comply with laws, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigations, enforce our TOS, and take other actions otherwise permitted by law.
External Links and Parties
Canada's Personal Information Protection and Electronic Documents Act
The Canadian government has enacted the Personal Information Protection and Electronic Documents Act (“PIPEDA”). PIPEDA outlines the way personal information may be used in Canada, and we fully adhere to it. You may at any time contact us regarding our use of your Personal Information by using the contact information referred to below or at the mailing address referred to below. You may contact us to provide you with more information in respect of our Privacy Statement and privacy practices, or to provide you with an opportunity to review your PII currently held by us and to request an amendment to the PII to correct any inaccuracies you determine are contained in such PII holdings. Where you demonstrate the inaccuracy or incompleteness of your PII held by us, we will correct or update the information as required. Please note that before we are able to provide you with any information or correct any inaccuracies we may ask you to verify your identity and to provide other details to help us to respond to your request. You are also entitled to request information as to the type of PII we have collected from you, how we have used your PII in the past and how we may use it in the future, and whether or not we have disclosed your PII to any third parties (and, if so, to whom).
There may be circumstances where we are unable to provide access to your PII. We may deny access for legally permissible reasons, such as situations where the information contains references to other individuals and is not reasonably severable, or where it cannot be disclosed for legal, security or other commercial proprietary reasons. We will advise you of any reason for denying an access request.
California Privacy Rights
Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice describing what categories of personal customer information we share with third parties for direct marketing purposes. That notice will identify the categories of information shared and will include a list of the third parties with whom it was shared, along with their names and addresses. If you are a California resident and would like a copy of this Privacy Statement, please submit a written request to the address listed below.
We are responsible for and will maintain and protect Personal Information in our possession or custody, including PII that we may transfer to third parties for processing. We have designed an individual or individuals who is/are accountable for compliance with this Privacy Statement.
To contact us concerning privacy issues, please send a letter to:
Attn: Privacy Officer
Roxi Communications, Inc.
243 Queen Street West
Email: [email protected]
Changes to This Privacy Statement
The Services are hosted in Canada. If you access our website or the Services from any jurisdiction with laws or regulations governing personal data collection, use, and disclosure that differ from the laws of Canada, please be advised that through your continued use of the Services, you are transferring your Personal Information to Canada and you consent to that transfer. Additionally, you understand that your Personal Information may be processed in countries (including the United States) where laws regarding processing Personal Information may be less stringent than in your country.
Governing Law and Dispute Resolution
How to Contact Us