Mobile Application Privacy Policy

Lakefront Utility Services Inc. (“Us”, “We”) is helping build a more efficient and interactive utility marketplace. Both businesses and individuals (“End Users”) can use the Application provided by the Lakefront Utility Services Inc. to help you understand your Lakefront Utility Services Inc.’s water and energy consumption through the tools and analysis provided (the “Services”).

Your Privacy Rights

Lakefront Utility Services Inc. and its solution provider, Screaming Power, complies with the Personal Information Protection and Electronic Documents Act (Canada) (“PIPEDA”), Municipal Freedom of Information and Protection of Privacy Act (MFIPPA) and the Digital Privacy Act, which amended sections of PIPEDA. We are responsible for the Personal Information we collect, use, maintain and disclose. We commit to using clear, simple language for the purpose of obtaining consent where ever needed. We follow reporting requirements in the event there is a breach of security safeguards involving Personal Information.

What is “Personal Information”?

Under PIPEDA and MFIPPA, Personal Information includes any factual or subjective information, recorded or not, about an identifiable individual. This includes information in any form, such as:

  • age, name, phone number, account number, address and GPS location;
  • IP address, browser/application type, operating system, pages/locations visited, the referring page, mobile carrier, device information, search terms and cookie information (“Log Data”);
  • energy usage;
  • opinions, comments, or reports (“Feedback”); and
  • any information that identifies you, or by which your identity could be deduced.

Personal Information does not include business related information such as: business address, business title, or business telephone numbers.

We make every effort to protect this sensitive information and we require consent whenever this information is  . The next section discusses consent in greater detail.

Consent

In most cases, we ask you to provide explicit consent when we collect, use, or disclose your Personal Information. Normally, we ask for your consent through the Application (the “Application”), but in some circumstances your consent may be implied through your conduct with Us and activity within the application.

The first level of consent is downloading the Application. The second level of consent is accepting the install on your device or accepting any terms and conditions. The third level of consent is (when available) creating an account and syncing Personal Information to cloud-based storage located within Canada (the “Cloud”). Within your personal account there are various ways of interacting with the Application. Application features may require Personal Information in order to provide you, the End User, with relevant and accurate information. For example, energy information is used to create customized content regarding energy consumption. The fourth and final level of consent that may be available within the application is with regard to consent to use data for research. If you choose, your Personal Information will be depersonalized by removing a sub-set of information, and generally assign you to a sub-grouping that depersonalizes the data (“Depersonalized Data”).

In the case of Personal Information, location, energy and building details and unique ID will be provided to Researchers and certain Third Parties approved by Lakefront Utility Services Inc. and can be used to provide you with specific research about your information. These IDs will be used to relay research back to the user within the Application.

Further information is available on the mobile Application or under the “Research Use” section of this privacy policy.

Collection of Your Personal Information

Primarily, We receive Personal Information from you, the End User, when you import Personal Information. At your discretion, you may provide information to customize your account, such as a cell phone number or email address. When you use the Application, you consent to the collection,  , storage, and disclosure of your Personal Information. This Personal Information not only includes the energy and property data you keep in the Application but other pieces of information that results from your use of the Application, such as how you navigate through the Application. Additional uses are described in the “Use of Your Personal Information” section of this privacy policy.

We also receive Personal Information from organizations/companies outside of the Lakefront Utility Services Inc. (“Third Parties”) who collect Personal Information and abide by their own privacy policies. These third parties can include a) parties that you have requested information from, b) parties that we use to create features or reports for your use, c) parties, including private and institutional, that we have agreements with to provide a service for the user or for  . All parties that are authorized will be required to abide by the same privacy policies that we abide by.

Lastly, We may collect Personal   from our Research Partners (Government, Colleges, Universities) (the “Researchers”). The research will be used by us to develop the Application and improve the Services. When the research is used by a Third Party, the Personal Information will be   at the user’s discretion (and is referred to in this privacy policy as Depersonalized Data). We ensure all companies/institutions that we transact with are operating in an ethical and legal way that corresponds to our corporate social responsibility. It is our purpose to use this information to better understand how to control and manage sustainability.

If you are unsatisfied with the Services provided to you by the Application, you may unsubscribe from all Services by using a note per contact details within the application.

Use of Your Personal Information

We use your Personal Information to improve the Services that are offered to you.

For the purposes of this privacy policy, “Shared Data” refers to your Personal Information if you provide consent to share that data with Third Parties and refers to Depersonalized Data where you have elected to depersonalize your Personal Information.

We use your Personal Information to customize the content that is displayed to you, including charts, reports and graphs. We will use your contact information to send you information about operations, products or services that are offered through us. When you sync, upload or manually enter information on the Application, We will use your Personal Information to assist with the consistency of your experience.

Your address, email and account information are key pieces of information for the use of the Application. Most of our Services are dependent on the use of this information. By uploading or manually entering your information, you are providing the Application with your personal details. This is a form of implied consent.

With regards to your GPS location and Log Data, We may use and store Log Data to provide you with additional services. Within the Application, you may have the option of services or information from us or Third Parties. In order to make this process efficient, We may use service providers to process and protect you from fraud. These service providers are subject to confidentiality agreements that are consistent with our privacy policy. When you activate services, personal information and transaction data is needed  by our solution to process and fulfill the request (the “Purchaser Information”) (e.g. signup process). The Purchaser Information is not used for any other purposes.

We receive Log Data when you interact with our Services and application, for example, when you use the Applications to sign-in to our Services, interact with our notifications or use your Lakefront Utility Services Inc. account to authenticate to a third-party website or Application. We may also receive Log Data when you click on, view or interact with a link on our Services to a Third-Party application.  We use Log Data to provide, understand, and improve our Services. We delete Log Data or remove any Personal Information after 24 months.

A cookie is a small data file that is transferred to your computer’s hard drive. Most internet browsers (e.g., Explorer, Chrome and Safari) automatically accept cookies. Application permissions are permissions set by the user when the application is installed on your device. Like many Applications, We use cookies, application permissions and similar technologies (such as APIs) to collect usage data and control third party device functions that improve our Services. Lakefront Utility Services Inc. may use both session cookies, persistent cookies and Application permissions to better understand how you interact with our Services, to monitor aggregate Application usage by our users and web or device traffic routing on our Services and to customize and improve our Services. You can instruct your browser or application (in settings in the case of a mobile application) to stop accepting cookies (or application authorizations) or to prompt you before accepting a cookie from the websites you visit. You can remove application permissions by changing them in your device settings area. However, some Services may not function properly or disable the features of the Application or service.

Your Feedback is used to improve our Services and make decisions on what research should be conducted.

Third Party Use

Lakefront Utility Services Inc. uses Third Party services to assist in providing our Services, such as hosting, APIs, Energy Utility Data retrieval to help Us understand and improve the use of our Services. These Third Party service providers may collect information sent by our Applications or your browser or third party applications as part of a request, such as Log Data. Third Party advertising partners may share information with Us, such as a browser cookie ID, website URL visited, mobile device ID, or cryptographic hash of a common account identifier (such as an email address). We may also receive information about you from our corporate affiliates in order to help provide, understand, and improve our Services and our affiliates’ services.

Research Use

We will continue to have associations and working relationships with institutions such as universities, governments and public utilities that may utilize your Shared Data for analysis, trends and insights. These parties also have their own privacy policies. The analysis is done by parties that are interested in assisting you the End User.  The research completed will be focused on reviewing opportunities for conservation, education, demand side management and behind the meter generation. Privacy and security of your Personal Information is of utmost importance and outcomes of research (if made public) will be aggregated and depersonalized to  ensure confidentiality.

Specifically, your Shared Data will reside in our servers for use and your authorized sharing of information. In the case of research, your Shared Data may be uploaded to a cloud at the research facility, (the “Researcher Cloud”), where the Researchers will have access to the Shared Data and abide by their privacy policies. The Researchers will use their own internal analysis tools. Any other tools that are used will be approved by the Lakefront Utility Services Inc. Once the Shared Data is added to the Researcher Cloud, Lakefront Utility Services Inc. and the Researchers will have access to the Shared Data and the research being performed. Please note these parties are governed by the privacy provisions of the Freedom of Information and Protection of Privacy Act (Ontario) (“FIPPA”). When We share information with research facilities, these parties will be required to report on and abide by their policies and procedures.

The research outcomes are to assist you, the End User, and educational institutions in understanding how to create conservative sustainable usage and enhance the use of green energy. A Researcher Cloud will only be available to the Researchers for the purpose of researching.

The Shared Data will be available to the Researchers for as long as research projects lasts. The current project is set to last 2 years (September 2017 – September 2019) and there is an option for extension. Any updates will be reflected in this Privacy Policy. Other research projects have been added as to enhance the use of the Shared Data and expand research potential. This research will be explained in areas of the Application.

Identified End Users (those who provided their address/GPS location and consented to sharing their Personal Information) will receive specific feedback regarding the results of the research and how it relates to their building/property. Anonymous participants (those who have not provided their address/GPS location and therefore their Personal Information was depersonalized into Depersonalized Data) will not benefit from specific feedback about their building/property, since We are unable to locate them. However, the anonymous participants may have access to the general results of our research.

Disclosure of Your Personal Information

Your Personal Information may be disclosed, without your consent, in the following circumstances, under PIPEDA  and MFIPPA:

  • Personal Information is contained in a witness statement that is necessary to assess, process or settle an insurance claim;
  • Personal Information is disclosed to a government institution if the disclosing organization has reasonable grounds to believe that the Personal Information relates to a contravention of the laws of Canada, a province or a foreign jurisdiction;
  • Personal Information is given to another organization and is reasonable for the purposes of investigating a breach of an agreement or a contravention of the laws of Canada, or for the purposes of detecting or suppressing fraud or of preventing fraud;
  • Use or disclosure of Personal Information is necessary in association with a prospective business transaction, so long as the Personal Information is safeguarded and the Personal Information is returned or destroyed if the transaction does not proceed.

If you consent to giving the Researchers access to some Personal Information, they can only disclose your Personal Information in accordance with  FIPPA.

This privacy policy will still apply to your Personal Information in the event of a bankruptcy, merger, acquisition, reorganization or sale of assets.

Further details regarding what can be disclosed can be found under section 7 (3) of PIPEDA.

We may also disclose Data to our corporate affiliates in order to help provide, understand, and improve our Services and our affiliates’ services, including the delivery of ads and information. This type of disclosure must be accompanied with your consent.

Security of Your Personal Information

To ensure the safety and protection of your Personal Information, Lakefront Utility Services Inc. takes the following precautions, in addition to adhering to PIPEDA and MFIPPA:

  • our Services on request will depersonalize Your Personal Information;
  • our Services use secure Hosting facilities where the data will be stored and used;
  • We use secure transport of data over the internet to and from the device and servers; and
  • any sharing of Information will be transported in a secure manner and be stored in a secure hosting facilities.

Updating Your Personal Information

Considering that We may use Personal Information to customize the content We show you, it is important that all Personal Information be accurate and up-to-date. If you are a registered user of our Services, We provide you with tools and account settings to access or modify the Personal Information you provided to Us. Lakefront Utility Services Inc. will do our best to make you aware of any Personal Information that is inaccurate, incomplete or out of date.

Deleting Your Account

You can permanently delete your Lakefront Utility Services Inc. account with us through the contact information within the application. When your account is deactivated, it is no longer viewable. The Personal Information that has already been collected and used for analysis will not be able to be withdrawn. For up to 30 days after deactivation, it may still be possible to restore your account if it was accidentally or wrongfully deactivated. After 30 days, We begin the process of deleting your account from our systems, which can take up to a week.

Access to Your Personal Information

You, the End User, can make a request to access Personal Information We hold about you. This Personal Information is saved on the Cloud, for as long as the End User allows or as stated in PIPEDA. However, your rights to Personal Information are not absolute and We may deny access when, as per PIPEDA  and :

  • denial of access is required or authorized by law;
  • the Personal Information is protected by solicitor-client privilege or, in civil law, by the professional secrecy of lawyers and notaries
  • to do so would reveal confidential commercial information;
  • to do so could reasonably be expected to threaten the life or security of another individual;
  • to do so would likely reveal Personal Information about a third party;
  • when granting you access would have an unreasonable impact on other people’s privacy;
  • to protect our rights and property; and
  • where the request is frivolous or vexatious.

If we deny your request for access to, or refuse a request to correct Personal Information, we shall explain why.

Further information is available under Section 9 of PIPEDA and section 38 of MFIPPA.

Additional Information

If you have the right to share your Lakefront Utility Services Inc. account to another person, service or application for the purpose of sharing tools or information, the other service may send Us your registration or profile information and other information that you have authorized through their application. Your information enables information sharing and helps Us improve the Services.

As long as authorized, you are free to share data and information about your usage with anyone as long as it is not used for business purposes. Be cautious about who you share your Personal Information with, as they may not treat your Personal Information with the same care that the Lakefront Utility Services Inc. does.

Learn more on how to manage your privacy and security in our Help area of the Application.

For information regarding Canada’s Anti-Spam Legislation (CASL), please go to:

http://fightspam.gc.ca/eic/site/030.nsf/eng/home

Changes to the Privacy Policy

We may revise this privacy policy from time to time. The most current version of the policy will govern our use of Personal Information and will always be accessible within or application. If We make a change to this policy that, in our sole discretion, is material, We will notify you via a twitter update, application notification or email the email address associated with your account. By continuing to access or use the Services after those changes become effective, you agree to be bound by the revised Privacy Policy.