2. Identifying PurposesUnless the purpose is self-evident due to the nature of the transaction in question, Zerofootprint will identify the purposes for which personal information is collected at or before the time the information is collected. The proposed purposes will be described in a reasonably understandable manner. An example of a self-evident purpose is requesting the name and address of the person placing an order in order to ensure proper delivery.
3. ConsentWe will collect, use or disclose your personal information only with your knowledge and consent, except where required or permitted by law. Zerofootprint will not make your consent a requirement to the supply of a product or a service other than as required to be able to supply the product or service. Consent can be expressed or, in some circumstances, implied, and given in writing, by using or not using a check-off box, electronically, orally (in person or by telephone), or by your conduct, such as use of a product or service. Zerofootprint assumes your implied consent to share some personal information, such as your name or nickname, photo, footprint, group memberships, and other profile-related information with other users of our websites and software. In some of our programs, you may choose to hide this information, as noted in the Types of Personal Information (Profile) section below. In others, such as VELObilltm Beta, this information will be public. In the full VELObilltm program, all information will be kept anonymous unless you choose to publish it. In determining the type of consent to obtain, Zerofootprint will consider all relevant factors, including the sensitivity of the information and your reasonable expectations. You may withdraw your consent at any time, on reasonable notice, subject to legal or contractual restrictions. Zerofootprint will inform you of the implications of doing so.
4. Limiting CollectionThe collection of personal information by Zerofootprint will be limited to what is necessary for the purposes which it identifies. We will collect personal information by fair and lawful means.
5. Limiting Use, Disclosure, and RetentionWe do not sell or rent customer lists or personal information to others. However, we may release your information to parties outside Zerofootprint in certain circumstances, which include: With your consent on an ongoing basis, we will disclose your personal information to other organizations or individuals as requested by you. We release only the information required to identify you, as well as the specific data collected by our software and websites for which you have given consent. It is important to understand the different ways that we may obtain your consent to collect, use, disclose and share your personal information. Depending on the situation and the sensitivity of the information, we may obtain your consent in different ways. Express consent may be obtained verbally, online or in writing. Implied consent may be obtained through your use of a product, or when you approach us to obtain products or services from us. We will not make your consent a condition of obtaining a product or service, unless it is reasonably or legally required, and we will clearly indicate when this is the case.
For servicing purposes We give a limited amount of information, only as necessary, without your consent, to our suppliers and agents. These suppliers and agents may be located in Canada or other jurisdictions or countries, and may disclose information in response to valid demands or requests from governments, regulators, courts and law enforcement authorities in those jurisdictions or countries. When required or permitted to do so by law or applicable regulators and self-regulatory organizations We may release information in response to a search warrant, court order, or other demand or enquiry which we believe to be valid. This may include requests from regulators, including self-regulators, who are responsible for ensuring Zerofootprint is in compliance with applicable regulations. We may disclose information to help us collect a debt owed to us by you. We may also disclose information to an investigative body in the case of a breach of agreement or contravention of law.
Transfers of a business As Zerofootprint continues to develop and grow, we may buy or sell parts of our businesses. A large portion of our businesses consist of the data collected by our software and websites, as well as our customer relationships, and personal customer information, which would generally be one of the transferred business assets.
6. AccuracyWe will keep your personal information as accurate, complete and up-to-date as necessary for the purposes for which it is to be used.
7. SafeguardsZerofootprint will protect personal information by security safeguards appropriate to the sensitivity of the information, including through the use of the following measures: physical (e.g., locked filing cabinets, restricted access, appropriate disposal of personal information), organizational (e.g., security clearances, access only on a “need to know” basis), technological (e.g., passwords, encryption) and training of employees.
8. OpennessInformation about our policies and practices relating to the management of personal information will be made readily available to individuals. Individual Access Upon request, Zerofootprint will inform you of the existence, use and disclosure of personal information relating to you, and give you access to that information. You have the right to challenge the accuracy and completeness of your information and have it amended as appropriate. However, in certain circumstances permitted by law, this information will not be disclosed to you. Some examples of these circumstances are information that contains references to other individuals that cannot be disclosed for legal, security or commercial proprietary reasons, or that is subject to solicitor-client or litigation privilege. We do not knowingly collect or solicit personal information from anyone under the age of seventeen or knowingly allow such persons to register. If you are under the age of seventeen, please do not attempt to register or send any information about yourself to us, including your name, address, telephone number, or email address. In the event that we learn that we have collected personal information from an individual under the age of seventeen, we will remove that information as quickly as possible. If you believe that we might have any information from or about a person under the age of seventeen, please contact us.
9. Contacting us and/or Challenging ComplianceFor anything to do with this Policy, including questions or comments, or to challenge our compliance with this Policy, please contact us as follows:
Privacy Officer, Zerofootprint Software Inc. 197 Spadina Avenue, Suite 400 Toronto, Ontario M5T 2C8 email: firstname.lastname@example.org
Zerofootprint will inform individuals who make enquiries or lodge complaints about its enquiry or complaint procedures, as applicable. If a complaint is found to be justified, we will take appropriate measures, including, if necessary, amending our policies and practices.
Of course, this Policy is subject to all applicable privacy laws in the Province of Ontario, Canada and Zerofootprint’s right to change it at any time.
Types of Personal Information
Zerofootprint is not in the business of selling personally identifiable information to others. Users’ specific personal information is not currently sold or rented but we may decide to do so in the future. If this were to happen, Zerofootprint would announce such a plan and ask you to “opt in”. If you wanted to share your personal information, you would have to respond. In the absence of such a response, your personal information would not be sold or rented to a third party.
The type of personal information which we collect from you depends on the type of transaction involved:
Whenever you visit Zerofootprint’s websites, Zerofootprint’s web server automatically recognizes and stores information, such as your IP address and domain name, and any referring websites. We use this information to understand visitor traffic patterns through our websites for purposes such as enhancing their usability. Your computer provides this information automatically each time you log on, unless you have activated the blocking technology available in some browsers.
For some programs, Zerofootprint asks for your name (or a nickname or location name), address, email address, and other personal information when you create an account online. When you use VELObilltm Beta and VELObilltm, Zerofootprint asks you to choose a nickname or place name, and for utility account numbers, utility passwords (providing access to utility online portals), house size, number of occupants, and zip code/postal code. When you provide Zerofootprint with your utility account information, you are consenting to Zerofootprint accessing your account for the purpose of obtaining your utility consumption data. You will also be asked for personal information when you make an online purchase, or enter into contests or promotions. This information is used to process your orders and to allow us to communicate with you. The information also enables Zerofootprint to customize products or services to better meet your preferences and to offer you products and services from Zerofootprint and other sources that may be of interest to you.
When you create a Registered User account for use in any of Zerofootprint’s websites or software, you may be provided with the opportunity to create a user profile about yourself. Profile information is used to be presented back to and edited by you when you access the service; and in addition, to be presented to others permitted to view that information by your privacy settings.
When you register with Zerofootprint as a Registered User, you create your own profile and privacy settings. Your profile information, as well as the name, nickname or location name you provide, photo (if you submit one), and footprint, are displayed to people using the Zerofootprint websites and software. You may be given a choice of whether or not you want this information shared on your profile, which you can set using the privacy settings on your profile. In the VELOtm program and VELObilltm Beta program, your profile will be public. In the full VELObilltm program, you will have the option to choose whether your profile information is public or private.
Zerofootprint may use information in your profile without identifying you as an individual to third parties. We do this for purposes such as aggregating the footprints of different geographic areas and personalizing advertisements and promotions. We believe this benefits you. You can know more about the world around you and, where there are advertisements, they are more likely to be interesting to you. For example, if you choose to make one of our tips into a goal, we might serve you an advertisement highlighting products or services which can help you to achieve it, but we will never tell the advertiser who you are.
You understand and give your consent that some of our services, including VELObilltm Beta and VELObilltm involve providing your data to Zerofootprint so that we can compare it to your peers to give you an idea of how your consumption compares to others. We will also use your data in an anonymized fashion to build a database of consumption patterns so that we can develop insights on energy use that will help our customers and partners find energy reduction and other business opportunities. When we conduct a comparison, all data will be provided anonymously, so that others will not be able to identify you based on the report we provide them. Likewise, you will not be able to identify your peers by a report we provide you.
You also agree that we may display your data on a map so that we can show geographic consumption patterns to you, our other customers as well as our partners. When we display maps to you, you may be able to see your specific consumption patterns, but any time we display your data to other parties, it will be anonymized to protect your privacy. By providing your data, you agree to us using your data in this fashion.
You post Submissions (as defined in the Terms of Service) on our services or websites at your own risk. Although we allow you to set some privacy options that limit access to your pages, please be aware that no security measures are perfect or impenetrable. We cannot control the actions of other Users with whom you may choose to share your pages and information. Therefore, we cannot and do not guarantee that the content you post on the Site will not be viewed by unauthorized persons. We are not responsible for circumvention of any privacy settings or security measures contained on the Site. You understand and acknowledge that, even after removal, copies of User Content may remain viewable in cached, archived or indexed pages on the Website or on Third Party Sites, or if other Users have copied or stored your User Content.
If you choose to use our invitation service to tell a friend about our software or website, we will ask you for your friend’s email address or Facebook profile name. We will automatically send your friend a one-time email inviting him or her to try the software or visit the website. Zerofootprint stores this information to send this one-time email and to track the success of our referral program. Your friend may contact us to request that we remove this information from our database by contacting the Privacy Officer listed in this Policy.
In some programs, access and control over most personal information is readily available through the profile editing tools. In others, such as VELObilltm Beta and other beta (test) versions, we may have to make changes for you manually. If profile control over personal information is available, you may modify or remove any of your profile information at any time by logging into your account and profile. Individuals may hide content including their footprint. If profile control is not available, you can contact product support or our Privacy Officer, noted above. If you wish to deactivate your profile, including your online account, please contact the Zerofootprint Community administrator for your product. For VELOtm and VELObilltm Beta, contact email@example.com. Removed information may persist in backup copies for a reasonable period of time but will not be generally available to visitors on the website.
Where you make use of the communication features of the service to share information with other individuals using our software or on our websites, however, (e.g., posting comments) you generally cannot remove such communications.
Promotional Offers – How to Unsubscribe
Occasionally we send promotional offers to selected groups of Zerofootprint customers for offers from Zerofootprint itself, or for offers where we have joined with another business for such promotions. When we do this, we do not give that business your name and address. Such offers will always contain an unsubscribe option so you may indicate if you do not wish to receive any future offers. Please allow up to 7 business days for such request to be processed.
Zerofootprint may also use personal account information and data collected through your personal identification to generate statistics and aggregate reports for internal use and for sharing with affiliates, subsidiaries, licensees, successors and advertisers. These statistics and aggregate reports will not contain any information that could identify you personally.