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Privacy Policy

Privacy Policy Your Privacy Matters

This Privacy Policy was last updated on August 1, 2018.

We care about your privacy. This Privacy Policy applies to the customers and authorized users of the products and services of Xplornet Communications Inc. and its subsidiaries, including the business unit operating under the Xplore Mobile name (collectively, “Xplornet”, “we” or “us”).

We understand your concerns about privacy and want to be transparent about our policies and procedures concerning the collection, use, disclosure and protection of your personal information, how we obtain your informed consent, how you can access your personal information and who to contact if you have any questions or concerns about your privacy. Please take the time to review the information below.

Protecting Your Privacy and Personal Information

Personal information is information about an identifiable individual or information that allows an individual to be identified. This may include information such as your name, mailing address, email address, telephone number, credit information, billing records or service information. Generally, personal information does not include business contact information or other exceptions created by law.

At Xplornet, we know that our customers trust us to maintain the privacy, accuracy and security of your personal information. We take this responsibility seriously.

To protect the confidentiality of your personal information, Xplornet employs technical, operational and administrative safeguards in its network and systems appropriate to the sensitivity of your personal information. Employees are trained and reminded of the obligations to protect your privacy and personal information. Where personal information is disclosed to third parties, we ensure through our contracts with them that there are comparable level of protections and safeguards.

To provide you with an increased level of security, online access to certain personal information may be protected with a password you select. We strongly advise that you do not share your password with anyone. Xplornet will not ask for your password in any unsolicited communication.

Consent

It all starts with your consent.

BY SUBMITTING PERSONAL INFORMATION TO XPLORNET OR ITS AGENTS OR BY OTHERWISE INDICATING YOUR CONSENT TO THIS PRIVACY POLICY, YOU AGREE THAT WE MAY COLLECT, USE AND DISCLOSE SUCH PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY AND AS PERMITTED OR REQUIRED BY LAW.

In addition, your consent to the collection, use or disclosure of your personal information may be implied or expressed, verbally, in writing, electronically (such as by ticking a box or button) or otherwise. We may imply your consent if it is reasonable in the circumstances. For example, if you provide your address, we may use it to send you bills or important notices related to your products or services. In other circumstances, we would ask for your express consent, such as before doing a credit check.

Sometimes, in specific circumstances, such as when it may be impossible or inappropriate to obtain your consent, privacy laws allow us to collect, use or disclose your information without your consent. For example:

  • if it is clearly in your interests (such as a medical emergency or a threat to your safety),
  • to comply with a warrant or order of a court or regulatory authority,
  • to collect a debt or to recover equipment that belongs to Xplornet,
  • to investigate a breach of an agreement or applicable law, or
  • as otherwise legally required or allowed.

Consent is not forever. You can withdraw your consent or opt-out of the collection, use or disclosure of your personal information, subject to legal and contractual requirements, by contacting Xplornet’s Privacy Officer. We respect your choice but if you refuse or withdraw your consent, we may not be able to provide you with the products, services or information which may be of value to you.

If you provide Xplornet or our agents with personal information of another individual (for example, an authorized user on your account), we ask you to respect their privacy and obtain all necessary consents from such person to enable us to collect, use and disclose their personal information for the purposes described in this Privacy Policy.

Collecting Personal Information

Xplornet’s goal is to connect you to what matters. Connecting people is personal and that means knowing certain personal information about you, including who you are (to establish your identity), where you are, how we can reach you, how you are paying for our products and services, and how we can improve your service or product experience.

We may collect personal information at various times during your relationship with Xplornet, including

  • when you provide your personal information during the inquiry, activation or purchase process for a product or service,
  • when we provide service to you, including technical support or warranty, repair or service claims,
  • when you use our products or services, visit our websites (such as through cookies or similar technologies), use one of our applications, call into a call centre, or shop in one of retail locations, or
  • from third-parties, such as credit reporting agencies, or other third-parties with whom you have had a payment relationship.

Using Personal Information

It is simple – we use your personal information to provide you with our products and services.

We may also use your personal information to:

  • establish and maintain our commercial relationship with you, provide ongoing services and provide information regarding your service (such as usage information or network status),
  • understand your needs and preferences as a customer, recommend products and services to meet your needs, and determine your location and eligibility for products and services,
  • develop, improve, market or provide new products and services,
  • manage and develop our business operations, ensure our networks are functioning, protect the integrity of our networks, or
  • meet our legal obligations and regulatory requirements.

We will request your consent, where necessary, before using your personal information for any new purposes beyond those described in this Privacy Policy.

Disclosing Personal Information

We may disclose your personal information in circumstances when we have your express or implied consent. We may also disclose your personal information:

  • to a person acting as your agent (such as an authorized user on your account or a legal representative) when, in our reasonable judgement, that person is authorized to receive your personal information,
  • to our suppliers, service providers and authorized agents who assist with activities related to providing you with service, such as service installation, network maintenance or payment processing,
  • to another communications service provider or a telephone directory service provider in order to offer you communications services (for example, to provide roaming services when you roam in another carrier’s coverage area),
  • to third-party collection agencies and third-parties, such as credit reporting agencies or anyone with whom you have had a payment relationship, to assess creditworthiness or to assist with the collection of amounts owed to Xplornet that are past due,
  • to delivery organizations to ship you products or provide services you have ordered,
  • to a government institution or another organization if reasonably necessary to establish your identity, to investigate a contravention of a law or an agreement, to prevent fraud, to comply with regulatory reporting requirements or to respond to a matter you initiated,
  • to an appropriate public authority in an emergency situation, such as where there is imminent danger to life or property,
  • to a third party to whom you have given consent (such as a financial institution or government agency) to receive your personal information, or
  • as permitted or required by law.

We will request your further consent, where necessary, before disclosing your personal information for any new purposes beyond those described in this Privacy Policy.

We may also de-identify, aggregate or anonymize personal information about our customers, such that it is no longer information about an identifiable person, and use that information to assess our network performance, manage our business, identify trends, develop statistical information, understand how we are performing, or develop new products or services. This information may also be shared with third parties for other analytical purposes and, because it no longer personally identifies any individual, it is not subject to or restricted by this Privacy Policy.

Our Websites

When you visit our websites, receive communications, visit our stores or follow links on our websites, you may encounter some of the following features intended to customize and improve your experience:

  • Cookies – We may use a browser feature called a “cookie” to collect information such as the Internet Protocol address, the type of Internet browser and operating system being used, the domain name of the website from which you linked to our websites, the date and duration of your visit, number of visits, time spent visiting our websites, pages viewed and number of cookies accumulated. We collect this information to help us understand and improve your experience on our websites.

A cookie is a small text file containing a unique identification number that identifies your browser, but not necessarily you personally, to our computers each time you visit our websites. Unless you provide personal information (such as by filling in a request to be contacted), we will not know who you are. You can make use of your browser settings to receive or refuse cookies. However, if you refuse to accept cookies, you may not be able to use some of the features available on our websites that may personalize your experience.

  • Beacons – Our websites may also use a technology called “Web Beacons”. This technology allows us to understand which pages you visit on our websites. These beacons are used to help us optimize and tailor your browsing experience for you and future visitors to our websites.
  • E-mail Communications – We may send e-mail communications to you, such as your monthly bill for services or, if you have consented, marketing information that may be of interest to you. In this process, we may collect certain information such as the date and time you first opened our e-mail communications, the number of times you open our e-mail communications, the number of click-throughs, total click-through activity on the contents of our e-mail communications and compile generally the related statistics. When aggregated for all customers, this information is used to manage and improve our communications to you.
  • Links – Our websites may contain links to other websites which are provided as a convenience only. Other third party websites may have different privacy policies than Xplornet and we have no responsibility for those third party websites.

Storage of Personal Information

Xplornet is proudly Canadian but the Internet and communications are global. We may transfer, store or process your personal information on servers in or outside Canada, including in the United States. While your personal information is subject to appropriate safeguards, it may be subject to the laws of the jurisdiction where it is held.

How Long is Personal Information Retained

We keep your personal information only as long as is reasonably necessary or relevant for the identified purposes in this Privacy Policy or as required by law. Once personal information is no longer reasonably necessary or relevant for the identified purposes, or required by law to be retained, your personal information is destroyed, erased or de-identified.

Accessing and Verifying the Accuracy of Your Personal Information

To provide you with a good service experience, we want your personal information to be accurate, complete and up-to-date. You may ask to review your personal information at any time and request to correct or update it, as appropriate, by contacting Xplornet’s Privacy Officer (please see contact information below). We may ask you to put your request in writing.

There may be certain circumstances where we cannot provide you with access to your personal information (for example, if it would involve the disclosure of someone else’s personal information or other confidential information) but, if that occurs, we will tell you the reason why.

Changes to Our Privacy Policy

Technology and our world continue to change and evolve. This Privacy Policy will inevitably need to change too and be updated to reflect changes to our personal information practices. We may change this Privacy Policy at any time and when we do, we will notify you by posting the change on our website and will make the revised policy available to you upon request to Xplornet’s Privacy Officer (please see below for contact information). You should regularly review the Privacy Policy to keep up to date on our personal information practices.

We Are Committed to Upholding this Privacy Policy

If you have any questions about privacy or your personal information, or wish to access your personal information, you can contact Xplornet’s Privacy Officer in writing by email at privacy.officer@corp.xplornet.com or by mail at 300 Lockhart Mill Road, Woodstock, New Brunswick, E7M 5C3.

More Information on Canada’s Privacy Laws

If you would like more information on Canada’s privacy laws or have a concern regarding Xplornet’s handling of your personal information that we have not addressed to your satisfaction, you can contact the Office of the Privacy Commissioner of Canada 30 Victoria Street Gatineau, Quebec K1A 1H3 Toll-free: 1-800-282-1376.