Updated as of November 14, 2017
Updated as of November 14, 2017
Purpose and Application
describe what types of Personal Information (as described below) we collect from customers, potential customers and visitors to our website and stores;
set out the purposes for which we use Personal Information;
identify the third parties to whom we disclose Personal Information;
describe how we safeguard Personal Information;
set out what rights you have regarding Personal Information; andlet you know how to contact us if you have questions or concerns
1. Being accountable
2. Identifying the purposes for Personal Information collection
3. Obtaining consent
4. Limiting the collection of Personal Information
5. Limiting the use, disclosure and retention of Personal Information
6. Keeping Personal Information accurate
7. Safeguarding Personal Information
8. Being open about policies and practices
9. Providing individual access to Personal Information
10. Challenging Compliance
Freedom Mobile and its affiliates may use Personal Information for the following purposes:
to conduct marketing research;
to send you marketing and other communications;
to understand your needs and preferences and your eligibility for our products & services;
to develop and enhance our products and services;
to provide you products and services, including sending and receiving confirmations, communications and bills, validating your identity, providing you support;
to respond to specific requests from you;
to administer and manage our business and operations, including the protection of the security and integrity of our services and our website; and
to meet legal and regulatory requirements.
We will only use your Personal Information for the purposes for which it was collected, and will only retain your Personal Information only as long as we require it for such purposes. Our general retention guideline is a 7-year period, which extends to all our corporate records including our customer & billing database. This allows us to meet our financial accountability and SOX audit obligations. Outside of the 7-year period, retention is defined based on length of time information is needed to meet the purpose(s) for which it has been collected and takes into account the sensitivity of the personal information. For example, we keep call records for 2 years, and IP logs for 180 days.
Freedom Mobile will automatically collect certain information such as Device location, Device type, and general usage information associated to the Media Access Control (“MAC”) address associated with your Device (the “Device Information”). The Device Information is used to deliver the Freedom Wi-Fi service, monitor and improve network traffic, improve your Freedom Wi-Fi experience and for research and statistical purposes. In certain instances, Freedom Mobile will rely on a third party to deliver Freedom Wi-Fi services at a specified location (for example, certain airports, universities or other public buildings). The relationship with the third party is governed by strict privacy provisions, in compliance with PIPEDA. As part of the delivery of the Freedom Wi-Fi services, the third party may have access to the Device Information, which can only be used for limited network monitoring and improvement purposes.
What are Cookies?
Cookies are small pieces of text containing unique identification numbers that identify a user's browser – but not the user personally – sent by their web browser by the websites they visit. A cookie file is stored in the user’s web browser and allows websites to recognize the user anonymously to assist in making their next visit to the website more useful for them.
When you use and access the Freedom Mobile website, we may place a number of cookies files in your web browser.
To enable certain functions of our site
To provide analytics
To store your preferences
We use different types of cookies:
Essential cookies. We may use essential cookies to authenticate users and prevent fraudulent use of user accounts.
Preferences cookies. We may use preferences cookies to remember information that changes the way the website behaves or looks, such as the "remember me" functionality of a registered user.
Analytics cookies. We may use analytics cookies to track information how the website is used so that we can make improvements. We may also use analytics cookies to test new promotions, pages, features or new functionality of the website to see how our users react to them.
In addition to our own cookies, we may also use various third-parties cookies to report usage statistics of the website and remarket our advertisements on other websites.
What are your choices regarding cookies?
Please note, however, that if you delete cookies or refuse to accept them, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages might not display properly.
For the Chrome web browser, please visit this page from Google: https://support.google.com/accounts/answer/32050
For the Internet Explorer web browser, please visit this page from Microsoft: http://support.microsoft.com/kb/278835
For the Firefox web browser, please visit this page from Mozilla: https://support.mozilla.org/en-US/kb/delete-cookies-remove-info-websites-stored
For the Safari web browser, please visit this page from Apple: https://support.apple.com/kb/PH21411?locale=en_US
For any other web browser, please visit your web browser's official web pages.
You can also opt-out of several third party ad servers' and networks' cookies simultaneously using a tool created by the Network Advertising Initiative located at http://www.networkadvertising.org/managing/opt_out.asp. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.
Disclosure of Information
Freedom Mobile may share Personal Information it collects to independent contractors of Freedom Mobile, subsidiaries and affiliates of Freedom Mobile, consultants, business associates, authorized retailers, dealers, suppliers, service providers, roaming partners, directory listing providers and credit and collection agencies, if and to the extent the disclosure will enable that party to perform a function related to one of the purposes described above.
Except as required or permitted by law, when disclosure is made to a third party other than a Freedom Mobile associate or affiliate, a third party service provider or roaming partner, the consent of the individual shall be obtained and reasonable steps shall be taken to ensure that any such third party has Personal Information privacy procedures and policies in place that are comparable to those implemented by Freedom Mobile. Such third parties are provided only with such information as is necessary in the circumstances. Personal Information provided to third parties may be used only for the purpose stipulated and is subject to strict terms of confidentiality.
We may from time to time engage in transactions such as the sale or securitization of assets, the sale of shares in our company, amalgamations and similar transactions and will disclose Personal Information to other persons in connection with their review of such a transaction.
We will also disclose Personal Information as required to meet legal and regulatory requirements or to support emergency calls (for example 911 calls).
Safeguarding Personal Information
Freedom Mobile primarily routes voice traffic on its wireless network internally and through domestic alternate carriers for back-up purposes. Voice traffic is routed outside of Canada when calls are made by Freedom Mobile customers to a non-Canadian destination or when a Freedom Mobile customer calls outside of Canada using their Device.
refuse to provide us with your Personal Information;
ask us for access to Personal Information that we hold about you;
ask us for information about our policies and procedures relative to the management of Personal Information
ask us to correct any inaccuracies or omissions in your Personal Information; or
ask us to remove Personal Information we possess, subject to reasonable notice, existing legal or regulatory obligations and our reasonable business requirements
However, we may not be able to offer you some of our services or functions of our website if you do not provide us with certain Personal Information or ask for your Personal Information to be removed. Marketing communications will only be sent to you if you elect to receive them when you register on our website or when you sign up for our services. You may opt out of receiving marketing communications at any time by selecting the “unsubscribe” option (in the case of e-mail communications), visiting our website or contacting our call centre.
Freedom Mobile complies with Canadian privacy law and take active steps to fully safeguard the information of our customers. At the same time we are compelled by law to respond to federal, provincial and municipal government and law enforcement agencies when they have a legally valid request ‐ like a search warrant or court order. Our customers' privacy is important to us and that is why we have issued a Transparency Report. This report is designed to provide more details on the number and types of requests we received in 2020. Download our 2020 Transparency Report.
Links to other sites
Chief Privacy Officer
Freedom Mobile Inc
16 York Street, Toronto, ON M5J 0E6
Canada or by email to firstname.lastname@example.org.