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INTRODUCTION OPN Technologies Inc. (“Company” or “we”) respects your privacy and is committed to protecting it. This policy describes our approach to privacy and how we treat your personal information. This policy describes: · The types of information we may collect or that app users (“you”) may provide when you download, register with, access, or use the OPN Mobile Application (the “App”); and · Our practices for collecting, using, maintaining, protecting, and disclosing that information. We will only use your personal information in accordance with this policy unless otherwise required by applicable law. We take steps to ensure that the personal information that we collect about you is adequate, relevant, not excessive, and used for limited purposes. Please read this policy carefully to understand our policies and practices for collecting, processing, and storing your information. If you do not agree with our policies and practices, do not download, register with, or use the App. By downloading, registering with, or using this App, you indicate that you understand, accept, and consent to the practices described in this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy ). Your continued use of this App after we make changes indicates that you accept and consent to those changes, so please check the policy periodically for updates.
· Non-personal information that does not directly or indirectly reveal your identity or directly relate to an identifiable individual, such as demographic information, or statistical or aggregated information. We may derive non-personal statistical or aggregated data from personal information. For example, we may aggregate personal information to calculate the demographics of users accessing a specific feature of the App. · Technical information, including your login information, device type, time zone setting, and usage details. Information You Provide to Us When you download, register with, or use this App, we ask you to provide: · Information by filling in forms in the App. For example, when you use this App to gain entry to a location you will be asked to complete a self-attestation form. We use this information to provide you, the organizations to which you are connected on the App, and such organizations’ administrator(s), with your current access status. That access status, which is used by your connected organizations’ administrator(s) to permit or deny you access to a location, is derived from your responses to the self-attestation form. · Information about your connected organizations. A connected organization is typically a company, institution, or other business that you (i) have a pre-existing relationship with and/or (ii) are seeking to physically enter. One example of a connected organization could be your employer/place of work. Another example of a connected organization could be a restaurant or retailer that you want to enter. · Information about your location from time to time. We use this information to determine which locations, buildings or facilities you are trying to enter. · Information when you report a problem with the App. We use this information to troubleshoot and help correct performance issues. In the future, we may also ask you to provide additional information about your health so that we can provide you, your connected organizations and their administrator(s), and other third parties with updates relating to your health status. We will always ask for your consent before we collect, use, or distribute such personal health information. Automatic Information Collection and Tracking Technologies When you download, access, and use the App, we may automatically collect: · Usage details. When you access and use the App, we may automatically collect certain details of your access to and use of the App, including location data, logs, and other communication data.
· Device information. We may collect information about your mobile device and internet connection, including the device's unique device identifier, operating system, browser type, and mobile network information. The information we collect automatically is statistical information and may include personal information. We may maintain it or associate it with personal information that you provide to us. This usage information helps us to improve our App and to deliver a more useful service, including by helping us to: · Estimate our audience size and usage patterns. · Store information about your preferences and customize our App according to your individual activity or behavior. · Speed up our services. · Recognize you when you use the App.
When you use the App or its contents, certain third parties may collect information about you or your device. These third parties include: · Your mobile device manufacturer. · Your mobile and internet service provider. · Our push notification service provider. · Our cloud storage service provider. · Our analytics and performance diagnostics providers. We do not control these third parties; tracking technologies or how they use them.
We use information that we collect about you or that you provide to us, including any personal information: · To provide you with the App and its contents. · To provide you and your connected organization(s) and their administrator(s) with your access status from time to time. · To provide your connected organization(s) and their administrator(s) with information regarding the days and times you enter and exit locations under their control. · To notify you when we require a new or updated self-attestation form. · To improve our App, products or services, or customer relationships and experiences. · For any other purpose with your consent. We will not use the information we have collected from you to display advertisements to you.
We may disclose aggregated information about our users that does not identify any individual. We may disclose personal information that we collect or you provide as described in this privacy policy: · To your connected organizations on the App and their administrator(s). · To comply with any court order, law, or legal process, including to satisfy the disclosure requirements of any governmental health agency, respond to any government or regulatory request, in each case according to applicable law. · To enforce our rights arising from any contracts between you and us, including the App’s Terms and Conditions.
We may process, store, and transfer personal information that we collect or that you provide to us, to service providers (such as cloud storage and push notification providers), and other third parties we use to support the App. We will take commercially reasonable steps to ensure that such service providers and other third parties treat your information confidentially and consistent with the terms of this privacy policy. We may process, store, and transfer your personal information in and to other countries with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information. Whenever we engage a service provider, we will take commercially reasonable steps to ensure that its privacy and security standards comply with this policy and applicable Canadian laws. We may disclose your information to other third parties in relation to a potential merger, acquisition, or sale of some or all of our assets or business. Your information may be provided to the entities and advisors conducting due diligence on any such transaction. You will be notified in the event any such transaction is completed, at which point your information may be transferred and the successor business may continue to use and disclose the information for the purposes described in this Privacy Policy.
· Access to your Camera. You can choose whether to allow the App to access your mobile device’s camera. If you do not allow access to your camera, some parts of the App may be inaccessible or not function properly.
The security of your personal information is very important to us. We use physical, electronic, and administrative measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. We store all information you provide to us either directly on your device or with our third-party cloud storage service provider(s). Information stored on your device (iOS or Android) is stored using a minimum AES-256bit encryption and in a secure hardware enclave located on your device. Information that is stored in the cloud is encrypted at rest and in transit and is stored using a minimum AES- 256bit encryption on the server. We only use cloud storage service providers that maintain high industry standards, including globally recognized security and data use & protection certifications.
Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize or aggregate your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.
Our App is not intended for children under 13 years of age. No one under age 13 may directly provide any personal information to or on the App. If you are under 13, do not use this App. If you are the parent or legal guardian of a child under 13 years of age, and you have been asked to use this App by your connected organization (e.g. a daycare, school, or club), then you may use this App and provide personal information about your child through your own account. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at privacy@stayopn.com. If you are between the ages of 13 and 18 you must fully review this Privacy Policy with your parent or legal guardian prior to using the OPN Mobile App.
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes. You have the right to request access to and to correct the personal information that we hold about you. If you want to review, verify, correct, or withdraw consent to the use of your personal information you may also send us an email at privacy@stayopn.com to request access to, correct, or delete any personal information that you have provided to us. We may not accommodate a request to change or delete information if we believe the change would violate any law or legal requirement, cause the information to be incorrect, or put the health or safety of others at risk. We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
Where you have provided your consent to the collection, use, and transfer of your personal information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us at privacy@stayopn.com. Please note that if you withdraw your consent we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you make your decision.
We may update our privacy policy from time to time. It is our policy to post any changes we make to our privacy policy on this page. By continuing to use the OPN Mobile App you are consenting to the Privacy Policy as of its most recent revision date. We include the date the privacy policy was last revised at the top or bottom of the policy. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you, and for periodically visiting this privacy policy to check for any changes.
We welcome your questions, comments, and requests regarding this privacy policy and our privacy practices.
Please contact us at: Attn: Privacy Officer OPN Technologies Inc. 345 Adelaide Street West, Toronto, Ontario, Canada Email: privacy@stayopn.com