Privacy Policy

Privacy Policy

 

Overview and scope

Skep Home Corp., a private Canadian federal corporation, having its offices at 3710 – 397 Front St. West, Toronto, ON, M5V 3S1 (“Skep“) recognizes the importance of an individual’s right to privacy and is committed to protecting the personal information that it collects, uses and discloses in providing investment advisory services and operating its business. This privacy policy (“Privacy Policy“) applies to users of Skep’s services anywhere [in Ontario Canada], including users of Skep’s apps, website (“Website” and “site“), features or other services. This Privacy Policy outlines how Skep collects and uses personal information of users to provide its services, including how it safeguards the privacy of such users. This policy also applies to those who provide information to Skep in connection with an application to use our services, or whose information Skep otherwise receives in connection with its services. All those subject to this policy are referred to as “users” or “you” for purposes of this Privacy Policy.

This Privacy Policy does not apply to personal information about Skep employment candidates or Skep employees, partners, or contracted staff, which is dealt with separately. If you apply to Skep for a job, Skep will need to consider your personal information as part of its application review process. Skep normally retains information from candidates after a decision has been made, unless you ask Skep not to retain the information. If Skep offers you a job, which you accept, the information will be retained in accordance with Skep’s privacy procedures for employee records.

Privacy rights and accountability

All Ontario businesses engaged in commercial activities must comply with Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA“). PIPEDA gives you rights concerning the privacy of your personal information. Skep is responsible for the personal information it collects and holds. To ensure this accountability, Skep has developed this Privacy Policy and has trained its partners and employees in respect of it.

Acceptance of Privacy Policy

By submitting your personal information to Skep, you signify your consent to the collection, use and disclosure of your personal information in accordance with this Privacy Policy. If you do not consent to the collection, use and disclosure of your personal information in accordance with this Privacy Policy, do not provide your personal information to Skep. Of course, certain services can only be offered to you if you provide personal information to Skep, and therefore Skep may not be able to offer you those services if you choose not to provide it with required personal information.

Personal information

PIPEDA defines “personal information” broadly as any information about an identifiable individual. Generally speaking, personal information does not include “business contact information” such as the name, job title, business address, or business telephone number of an employee of an organization.

Consent

Skep obtains your consent before it collects, uses, or discloses your personal information. Normally, Skep asks for your consent in writing, but in some circumstances, it may accept your oral consent. Sometimes, your consent may be implied through your conduct with Skep.

Subject to legal and contractual requirements and reasonable notice, you may refuse or withdraw your consent to certain of the identified purposes at any time by contacting Skep’s Privacy Officer (see the end of this Privacy Policy for contact information). The period of reasonable notice will vary depending on the nature of the information and its purpose.

If you provide Skep or its service providers and agents with personal information of another individual, you represent and warrant that you have all necessary authority and/or have obtained all necessary consents from such person to enable Skep to collect, use and disclose such personal information for the purposes set forth in this Privacy Policy.

There may be circumstances where you have provided personal information for an identified purpose, and Skep later needs to use that information for a different purpose. In such circumstances, Skep will seek your consent to use the information for the new purpose.

Why Skep collects, uses and discloses your personal information

Skep collects:

  • Information that you provide to Skep, such as when you create your Skep account.
  • Information created when you use our services, such as location, usage and device information.
  • Information from other sources, such as Skep partners and third parties that use Skep application programing interfaces (APIs).

The following information is collected by or on behalf of Skep:

  1. Information that you provide

This may include:

    • User profile: We collect information when you create or update your Skep account. This may include your name, email, phone number, login name and password, address, payment or banking information (including related payment verification information), government identification numbers such as social insurance number, driver’s licence or

passport, birth date, photo and signature. This also includes the preferences and settings that you enable for your Skep account.

    • Background check information: We may, through our third party service provider, collect background check information if you sign up to use Skep’s services as a cleaning service provider. This may include information such as your work history or criminal record (where permitted by law). This information may be collected by a third party service provider on Skep’s behalf.
    • Demographic data: We may collect demographic information about you, including through user surveys. In some countries, we may also receive demographic information about you from third parties.
    • User content: We may collect information that you submit when you contact Skep customer support, provide ratings or compliments for other users, or otherwise contact Skep.
  1. Information created when you use our services

This may include:

    • Location Information

Depending on the Skep services that you use, and your app settings or device permissions, we may collect your precise or approximate location information as determined through data such as GPS, IP address and WiFi.

      • If you are a cleaning service provider, Skep collects location information when the Skep app is running in the foreground (app open and on-screen) or background (app open but not on screen) of your device. Skep also collects social insurance numbers to set up accounts with our third party payment provider.
      • If you are a recipient of the cleaning services and have provided permission for the processing of location data, Skep collects location information when the Skep app is running in the foreground.
    • Transaction Information

We collect transaction details related to your use of our services, including the type of services you requested or provided, your order details, delivery information, date and time the service was provided, amount charged, distance traveled, and payment method. Additionally, if someone uses your promotion code, we may associate your name with that person.

    • Usage information

We collect information about how you interact with our services. This includes information such as access dates and times, app features or pages viewed, app crashes and other system activity, type of browser, and third-party sites or services you were using before interacting with our services. In some cases, we collect this information through cookies, pixel tags, and similar technologies that create and maintain unique identifiers. To learn more about these technologies, please see our Cookie Statement.

    • Device Information

We may collect information about the devices you use to access our services, including the hardware models, device IP address, operating systems and versions, software, file names and versions, preferred languages, unique device identifiers, advertising identifiers, serial numbers, device motion information, and mobile network information.

    • Communications data

We enable users to communicate with each other and Skep through the Skep apps, websites, and other services. To provide this service, Skep receives some information regarding the calls or texts, including the date and time of the call/text, and the content of the communications. Skep may also use this information for customer support services (including to resolve disputes between users), for safety and security purposes, to improve our products and services and for analytics.

  1. Information from other sources

These may include:

    • User feedback, such as ratings or compliments.
    • Users providing your information in connection with referral programs.
    • Users requesting services for or on your behalf.
    • Users or others providing information in connection with claims or disputes.
    • Skep business partners through which you create or access your Skep account, such as payment providers, social media services, on-demand music services, or apps or websites who use Skep’s APIs or whose API Skep uses.

Skep collects and uses information to enable reliable and convenient [third party] services and other related products and services. Skep collects, uses and discloses your personal information for the purposes identified at the time of collection, or as otherwise permitted or required by applicable law, including for the following purposes.

    • to communicate with you regarding the services we provide;
    • to enable communications to and or between users;
    • for research and development;
    • for customer support;
    • to evaluate your satisfaction with our services and conduct market research;

•toprovidepromotionsorcontests;

 

  • to maintain and develop its systems and databases for managing documents and knowledge;
  • to detect and protect against error, negligence, breach of contract, fraud, theft and any other illegal activity, and where necessary to meet its insurance requirements;
  • to send you information about Skep’s products and services and about developments in markets, to invite you to Skep events and to communicate with you generally;
  • to help Skep evaluate and modify existing and, as applicable, new services or products;
  • to enhance the safety and security of our users and services;
  • as permitted by, and to comply with, applicable legal or regulatory requirements; and
  • to further any other purpose for which it has your consent.

 

Skep may also ask for and collect your personal information at certain points throughout the services it provides. In addition to the information you knowingly provide, Skep collects the domain names and IP addresses of its visitors, along with usage statistics (e.g., types of web browsers and operating systems used) and browsing history. This data is used to more efficiently operate Skep’s business and to promote and administer our services. As well, Skep collects any information you may choose to provide in your communications with us.

How Skep collects, uses and discloses your personal information

Skep collects your personal information by fair and lawful means and, wherever appropriate, directly from you. Wherever possible, Skep limits the amount of personal information it collects, uses or discloses to that necessary and appropriate to provide its services and to operate Skep’s business. Skep does not sell or share your personal information to third parties for third party direct marketing purposes. Skep uses the information for the various purposes, including:

  1. Providing Services and Features to Your Account

Skep uses the information it collects to provide, personalize, maintain and improve its products and services. This includes using the information to:

    • Verify your identity.
    • Create and update your account.
    • To enable third party services to be transacted.
    • Process or facilitate payments for those third party services.
    • To track progress or status of the third party services.
    • Enable features that allows you to personalize your Skep account or to share your information with other people.
    • Perform internal operations necessary to provide our services, including to troubleshoot software bugs and operational problems, to conduct data analysis, testing, and research, and to monitor and analyze usage and activity trends.

2. Communications between Users

Skep uses the information it collects to enable communications between its users. For example, a cleaning service provider may text or call to confirm a location for the cleaning services.

  1. Communications between Skep and Users

Skep may use the information it collects to communicate with you about products, services, promotions, studies, surveys, news, updates and events.

Skep may also use the information to promote and process contests and sweepstakes, fulfill any related awards, and serve you relevant ads and content about our services and those of our business partners. You may receive some of these communications based on your profile as a Skep user.

Skep uses the information it collects (including recordings of customer support calls after providing notice to you and with your consent) to assist you when you contact our customer support services.

Skep may use the information it collects for testing, research, analysis and product development. This allows us to improve and enhance the safety and security of our services, develop new features and products, and facilitate insurance and finance solutions in connection with our services.

We use your data to help maintain the safety, security and integrity of our services and users.

  1. Legal Proceedings

Skep may use the information it collects to investigate or address claims or disputes relating to your use of Skep’s services, or as otherwise allowed by applicable law, or as requested by regulators, government entities, and official inquiries.

When Skep discloses your personal information

Skep discloses your personal information only as described in this Privacy Policy, with your consent, or as otherwise permitted or required by law. Under certain circumstances and consistent with PIPEDA, Skep will disclose your personal information, including:

    • if Skep engages a third party to provide administrative services to it (like computer back- up services or archival file storage) and the third party is bound by this Privacy Policy;
    • when necessary to collect outstanding accounts;
    • with other users in accordance with the services we provide;
    • with our subsidiaries and affiliates to help us provide our services or conduct data processing on our behalf;

•when necessary to comply with court orders, regulatory rules, or to satisfy Skep’s insurancerequirements;

 

  • to its vendors, consultants, marketing partners, research firms, and other service providers or business partners such as Stripe; and
  • when Skep reasonably believes that a third party requesting your personal information is your agent.

 

Please note that there are circumstances where the use and/or disclosure of personal information may be justified or permitted or where Skep may or must disclose information without your consent, in accordance with applicable law. For example, Skep may disclose your personal information to a government institution that has asserted its lawful authority to obtain the information or where Skep has reasonable grounds to believe the information could be useful in the investigation of unlawful activity, or to comply with a subpoena or warrant or an order made by a court, person or body with jurisdiction to compel the production of information, or to comply with court rules regarding the production of records and information, or to protect Skep’s rights and property. Where obliged or permitted to disclose information without consent, Skep will not disclose more information than is required for the purpose that obligates or permits it to disclose such information.

Disclosure of your personal information to third party service providers

When Skep transfers your personal information to a third party to provide administrative and other services, it uses appropriate measures to ensure that the third party will only use your personal information to perform the services Skep has specified. The increasingly global nature of Skep’s business sometimes requires it to use administrative service providers who may be located in the United States or elsewhere outside of Canada. Accordingly, your personal information may be transferred outside of Canada and if so, it will be subject to the legal requirements of the applicable foreign jurisdictions, including local requirements to disclose information to courts, law enforcement and national security authorities.

To the extent Skep enters into arrangements with service providers, agents and contractors to store, handle or process personal information on its behalf, such as for data processing, document storage software support and office services, Skep’s policy will be to require such parties by contractual or other means to provide comparable privacy protection while the information is processed or handled by them.

Where Skep stores your personal information

Your personal information is stored in secured locations and on servers controlled by Skep, located either at our offices or at the offices of our service providers. Your personal information may be processed, accessed and/or stored in Canada or another jurisdiction, and will be subject to the laws of that jurisdiction.

Security of your personal information

Skep uses commercially reasonable standard safeguards applicable to the technology services industry to protect the security of personal information in its possession, including physical, organizational and technological measures. These measures include:

    • premises security;
    • restricted access to files that contain personal information;
    • technological safeguards like security software and firewalls to prevent hacking or unauthorized computer access; and
    • internal password and security policies.

However, no method of transmitting or storing information is completely secure. While Skep takes appropriate measures to protect your personal information, there is always a risk that it may be lost, intercepted or misused. Skep may exchange electronic versions of documents and e-mails with you using commercially available software that may be vulnerable to attack by viruses and other destructive electronic programs. Skep cannot guarantee that all communications and documents sent via e-mail will always be received, or that such communications and documents will always be virus free. Skep makes no warranty with respect to the integrity of any electronic communications between Skep and you or with respect to the security of any such communication and you consent to Skep’s exchange of electronic communications, including confidential documents, unencrypted.

Accessing your personal information

You may ask for access to any personal information Skep holds about you. Summary information is available on request.

Subject to certain exceptions prescribed by law, you will be given reasonable access to your personal information and will be entitled to challenge the accuracy and completeness of that information and, to the extent that you have proven such inaccuracy or incompleteness, have it amended as appropriate. Examples of such exceptions include information that is prohibitively costly to provide, information that contains references to other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons, and information that is subject to solicitor-client or litigation privilege.

Updating the accuracy of your personal information

You can help Skep maintain the accuracy of your personal information by notifying Skep of any changes to your personal information. If Skep holds information about you and you advise us that it is not accurate, complete and up-to-date, Skep will take reasonable steps to correct it.

Being denied access to your personal information

Your rights to access your personal information are not absolute. Skep may deny access when:

    • denial of access is required or authorized by law;

information relates to existing or anticipated legal proceedings against you;

 

  • granting you access would have an unreasonable impact on other people’s privacy;
  • protecting Skep’s rights and property; and
  • your request is frivolous or vexatious.

 

If Skep denies your request for access to your personal information, or refuses a request to correct information, Skep will explain why.

Personal information

Cookies

We and our partners may use cookies and other identification technologies on our apps, websites, emails, and online ads for purposes described in this policy. Cookies are small text files that are stored on your browser or device by websites, apps, online media, and advertisements. Skep uses cookies and similar technologies for purposes such as authenticating users, remembering user preferences and setting, monitoring and analyzing site traffic and trends.

The use of cookie technology is common on the Internet, and many Internet browsers are initially set to accept cookies automatically.

If you would prefer not to accept cookies, you can set your Internet browser to notify you when your computer is receiving a cookie or to refuse cookies automatically. To readjust your Internet browser’s cookie options, please refer to the instruction documentation of your particular browser or seek online assistance.

Through the use of our services and site we may make use of “per session” and “persistent” cookie technology. Per session cookies track information during an open session and are stored only temporarily in your computer’s memory. Persistent cookies are deposited on a visitor’s computer until they expire or until the visitor deletes the cookies. Information from these cookies help Skep analyze traffic patterns to the site, including the total number of visitors, the geographical location of the visitor, and the types of Internet browsers (e.g., Google Chrome or Internet Explorer) and operating systems (e.g., Windows or Macintosh) that the site’s visitors use. Skep uses this information to facilitate and enhance your online visits. Skep does not cross- reference this information with any type of personal information that is voluntarily offered by you.

Traffic patterns

Monitoring and managing site traffic patterns, usage and related site information is done in order to optimise its web service. Skep may provide aggregated information to third parties, but these statistics do not include any personal information.

Tracking information

In addition, Skep may use non-personal information to create aggregate tracking information reports regarding user demographics and traffic patterns. None of the tracking information in the reports can be connected to the identities or other personal information of individual users. Skep also may link tracking information with Website users’ personal information. Once such a link is made, all of the linked information is treated as personal information and will be used and disclosed only in accordance with this Privacy Policy, and in accordance with the law.

Links

Any use of the Skep’s apps, site or services may present links to other websites. You should be aware that operators of linked websites may also collect your personal information and information generated through the use of cookies when you link to their websites. Skep is not responsible for how such third parties collect, use or disclose your personal information, so it is important to review their privacy policies before providing them with your personal information.

Serious privacy breach notifications

Skep will notify you of any breach of the security safeguards involving your personal information under Skep’s control if it is reasonable in the circumstances to believe that the breach creates a real risk of significant harm to you (a “Serious Privacy Breach“). This notice will be conspicuous and given to you in the manner prescribed under PIPEDA as soon as feasible after Skep determines that such a breach has occurred.

Likewise, Skep will report any Serious Privacy Breach to the Office of the Privacy Commissioner of Canada in the manner prescribed under PIPEDA as soon as feasible after Skep determines that such a breach has occurred.

Changes to Privacy Policy

Privacy laws are rapidly evolving and, as a result, Skep reserves the right to change this Privacy Policy without notice and at any time. The most current version of this Privacy Policy is posted on the Website. Regardless of any changes Skep makes to this Privacy Policy, Skep will only use your personal information in accordance with the version of the Privacy Policy in place at the time you provided your information, or as otherwise required or permitted by law, unless you have given your express consent for Skep to do otherwise.

Privacy Officer and requests, questions and challenges under Privacy Policy

Individual clients may review any personal information concerning themselves that Skep has on file in its offices by contacting their Skep advisor or Skep’s Privacy Officer at the address below. Individuals who are not clients may request access to personal information Skep holds about them by written request to:

Privacy Officer, Skep Home Corp.,

Support@skephome.com

If you are not satisfied with Skep’s response, the Privacy Commissioner of Canada can be reached at:

112 Kent Street

Place du Ville Tower, 3rd Floor Ottawa, Ontario K1A 1H3 1.800.282.1376

Effective date

This Privacy Policy was last updated and is effective as of July 23, 2020.

© 2020 Skep Home Corp. All rights reserved. Reproduction in whole or in part without permission is prohibited.