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Our Commitment

At Pungle, we are committed to protecting your privacy and maintaining strong practices in the handling of personal information in our care.

Pungle Canada Inc. (“Pungle”) has developed this Privacy Policy (the “Policy”) in accordance with applicable privacy legislation. By visiting the Pungle website (the “Site”) and/or providing your Personal Information (as defined in the following Section; “What is Personal Information?”) in order to register to receive information about the Pungle platform, or create an account on the Site you consent to Pungle collecting, storing, using and disclosing your personal information in accordance with the terms of this Policy. Updates to the Policy will be posted on the Site.

If you do not agree with the terms of this Policy, do not access the Site. If you are under eighteen years of age, you may not submit Personal Information to Pungle.

You may request your account closed at any time by sending an email to info@pungle.ca. The Policy shall apply in respect of all Personal Information received over the course of your relationship with Pungle, prior to the account being closed.

This Policy applies to the personal information of Pungle’s customers and other individuals we deal with.

 

What is Personal Information?

Section 2(1) of the Personal Information Protection and Electronic Documents Act (2000, c. 5) (PIPEDA) states that “personal information” means “information about an identifiable individual.” To this end Pungle defines Personal Information as any information we collect, use or disclose in the course of our activities.

This Policy applies to the personal information of Pungle’s customers and other individuals we deal with. This Policy does not apply to personal information of our employees or employee applicants, or to information that is not personal information. Personal Information does not include information that is anonymous, aggregated, or is no longer identifiable to a specific person.

 

Privacy Principles

Pungle follows the PIPEDA fair information principles to govern our privacy policy. These principles are:

Principle 1 – Accountability

An organization is responsible for personal information under its control and shall designate an individual or individuals who are accountable for the organization’s compliance with the following principles.

Principle 2 – Identifying Purposes

The purposes for which personal information is collected shall be identified by the organization at or before the time the information is collected.

Principle 3 – Consent

The knowledge and consent of the individual are required for the collection, use, or disclosure of personal information, except where inappropriate.

Principle 4 – Limiting Collection

The collection of personal information shall be limited to that which is necessary for the purposes identified by the organization. Information shall be collected by fair and lawful means.

Principle 5 – Limiting Use, Disclosure, and Retention

Personal information shall not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Personal information shall be retained only as long as necessary for the fulfillment of those purposes.

Principle 6 – Accuracy

Personal information shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.

Principle 7 – Safeguards

Personal information shall be protected by security safeguards appropriate to the sensitivity of the information.

Principle 8 – Openness

An organization shall make readily available to individuals specific information about its policies and practices relating to the management of personal information.

Principle 9 – Individual Access

Upon request, an individual shall be informed of the existence, use, and disclosure of his or her personal information and shall be given access to that information. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

Principle 10 – Challenging Compliance

An individual shall be able to address a challenge concerning compliance with the above principles to the designated individual or individuals accountable for the organization’s compliance.

 

Data Collected

Pungle collects certain information that can identify you as a specific individual (“Personal Information”) and non-personally identifiable information (“Non-Personal Information”) (collectively referred to “Information”) in order for you to register to receive information from Pungle, or open an account. Personal Information is collected when provided by you.

We do not knowingly collect Personal Information from anyone under eighteen years of age.

Information we may collect includes the following, but is not limited to:

  • Name, date of birth, address, occupation, email address, phone number, and other contact particulars;
  • Credit card information including card number, expiry date, security code, billing address, transaction history, and similar information;
  • Credit history and financial and identity information from consumer and credit reporting agencies, or financial institutions or businesses that you currently have, or have had, financial dealings with;
  • Income information, including the name and contact information of your employer or other source of income;
  • Banking information collected from your physical or online bank statements;
  • Information relating to ongoing interactions with Pungle, including payment history, inquiries or complaints, and similar information;
  • Social Insurance Number, and other personal identifiers (if you choose to provide them to us). If you give us your Social Insurance Number, we may use it to identify you with consumer reporting agencies and other parties, and we may keep it in our records with your other information, even after your account is closed;
  • Information we collect automatically when you visit our website; and
  • Other information with your consent (written or implied) or as permitted or required by law.

 

Consent

We will seek consent before collecting Personal Information. Generally, you will be asked to provide written consent, but in some circumstances, we may accept verbal consent or determine that consent is implied through your conduct.

 

Personal Information: Collection, Retention and Use

Pungle will only use your Personal Information for the purposes for which it was provided based on your written or implied consent. Pungle collects Personal Information when you provide it to sign up to receive information from Pungle, to create an account, complete your profile, access and use the Site, and when you communicate with Pungle. Personal information is used by Pungle to register you to receive information about the platform, create your account, populate and maintain your profile, to protect you and us from theft, fraud, and unauthorized access to your account, and provide information to you or otherwise communicate with you for each of these purposes.

During the receipt or transmission of your Personal Information by Pungle to its service providers as part of normal course of business, we will apply privacy safeguards and will only do business with companies who have committed to safeguarding Personal Information at similar standards applied by Pungle.

Personal Information may also be used by Pungle for customer service and marketing purposes, including to let you know of new products and services, and notify you of special offers. You may opt-out of marketing communications at any time by sending an email with “Unsubscribe” to the email address provided in the marketing communication.

 

 

Non-Personal Information: Collection, Retention, and Use

Non-Personal Information is collected when you visit the Site through cookies or similarly purposed technologies, including technical and statistical information such as include your IP address, mobile device identifiers, operating system, and page views and duration.

Non-Personal Information is used by Pungle for its business operations and planning, including the protection of you and us from theft, fraud, and unauthorized access to your account, the operation and improvements to the Site, debugging, product research, evaluation and development. While this information is related to you, it is not personally identifying information.

 

Disclosure of your Information

Pungle will not disclose your Personal Information to any third party in a way that is personally identifiable to you or any other specific user other than as specifically outlined in this Privacy Policy. Pungle does not sell your Personal Information to any third party. Pungle may disclose and share your Personal Information with any third party as required to process your requests and the transactions requested by you, and with companies providing related services to Pungle.

Pungle may share with any third party that it deems appropriate, aggregate anonymized information regarding the Site and users of the Site, such as demographic and geographic territory of end users, customer preferences, technical performance and usage statistics. These third parties may include, for example, business partners or companies who assist Pungle in providing or supporting the Pungle platform.

Pungle may share any personal or non-personal information if required by law, if it believes it is required to do so in order to comply with an order of a court of competent jurisdiction or other legal requirements of any governmental authority, it if believes doing so would potentially mitigate its liability in an actual or potential lawsuit, if it believes it is necessary to protect its rights or property, or if Pungle sells its business to a third party.

 

Data Protection and Security

Pungle takes your privacy and the protection of your Information seriously, and takes commercially reasonably measures to ensure its security. However, no transmission of Information over the Internet can be guaranteed to be uninterrupted or completely secure, and accordingly Pungle can not, and does not, guarantee that your Information will not be unlawfully accessed by a third party. PUNGLE DOES NOT WARRANT THE SECURITY OF ANY INFORMATION YOU TRANSMIT ELECTRONICALLY, AND YOU DO SO AT YOUR OWN RISK.

 

Contact Us

Pungle will take all your privacy inquiries very seriously. Should you have any concerns regarding how your Personal Information is used, collected and disclosed, you may send an email to privacy@pungle.ca. Or write to:

Pungle Canada Inc.

Suite 400 – 46 Spadina Avenue

Toronto, ON

M5V 2H8

Office of the Chief Privacy Officer

 

If your concern remains unresolved by the Office of the Chief Privacy Officer, you may contact the Office of the Privacy Commissioner of Canada (OPC). The OPC oversees compliance with the Personal Information Protection and Electronic Documents Act (PIPEDA), Canada’s private sector privacy law. You have the right to complain at any time to the OPC about any alleged mishandling of your personal information under PIPEDA.

Office of the Privacy Commissioner of Canada

3rd Floor, Place de Ville

112 Kent Street

Ottawa, Ontario

K1A 1H3

Call: 1-800-282-1376

Visit: priv.gc.ca

 

Governing Law and Jurisdiction

Pungle Inc. is domiciled and provides its services in the Province of Ontario. Consumers from countries and jurisdictions outside of Canada are advised that this Policy, and the collection, retention, and use of your Information, shall be construed in accordance with and governed by the laws of the Province of Ontario and the federal laws of Canada as applicable.

You are also advised that Personal Information and Non-Personal Information is retained in cloud-based servers which may be located in Canada, the U.S.A. and other jurisdictions. You acknowledge and agree that: (i) by providing Personal Information to Pungle you consent that such Information be transferred through and to the third party services providers selected by Pungle at its absolute discretion, and shall be treated in accordance with the laws of Canada, which may offer less stringent consumer rights than the jurisdiction in which you reside, and (ii) for commercial and security reasons, the location of the servers storing Information at any given time is deemed to be confidential information of Pungle and will not be disclosed to you.

 

Changes to this Policy

Pungle may revise this Policy from time to time. Changes and the updated Policy will be published on the Site, and identified by the publication date. Please revisit this page and review the Policy during your use of the Site and Pungle services to ensure that you are aware of the Information collected, retained, and used, and the authorizations granted by you pursuant to this Policy. Your continued use of the Site or the Pungle platform following the publication of an update to this Policy confirms your acceptance of the then updated Policy terms.

 

Opting out of Marketing Communications

To opt-out of marketing communications please send an email with “Unsubscribe” in the subject line to the email address provided in the communication.

 

Contact Pungle

Should you have any questions regarding this Policy, please contact Pungle Inc. at legal@pungle.ca.