Mobile App Privacy Policy

CBCRA: Recycle Everywhere Mobile Application

Last Revised: March 8, 2021

We at the Canadian Beverage Container Recycling Association (the “CBCRA”, “we” or “us”) respect your privacy and are committed to protecting it by complying with this policy.

Privacy laws in Canada generally define “Personal Information” as any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person. We will only use your personal information in accordance with this policy unless otherwise required by applicable law.

Please read the following to learn more about our privacy practices that govern your use of our Recycle Everywhere mobile application (the “App”), including your participation in any optional contests offered through the App (the “Contests”). By using or accessing the App or the Contests (collectively, the “Services”) in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy, and you hereby consent to the collection, use, and disclosure of your Personal Information in accordance with this Privacy Policy.

Remember that your use of the App is at all times subject to the Recycle Everywhere Mobile Application Terms and Conditions of Use (“Terms of Use”). To the extent you use the App to participate in any Contests, your use of the App will also be subject to the Contest Rules. Any terms we use in this Privacy Policy without defining them have the definitions given to them in the Terms of Use.

Your privacy is important to us. The purpose of this Privacy Policy is to tell you how we handle your Personal Information when you use the Services.

What does this Privacy Policy cover?

This Privacy Policy covers our treatment of Personal Information that we gather when you are accessing or using the Services, but does not cover the practices of companies we don’t own or control, or of people we don’t manage.

As explained in more detail below, we gather various types of Personal Information from our users, and use this Personal Information in connection with our Services–for example, to provide basic functionality, to allow you to set up a user account and profile, to personalize and improve the Services, to contact you and allow other users to contact you, to fulfill your requests for certain products and services, and to analyze how you use the Services. In certain cases, we may also share some Personal Information with third parties, but only as described below.

 

Will we ever change this Privacy Policy?

We may need to change this Privacy Policy from time to time, but we will alert you to changes by posting the revised Privacy Policy and changing the “Last Revised” date at the top.

If we make any changes to this Privacy Policy that affect how we collect, use or disclose your Personal Information, we will also update you via an in-app notification or by email at the last email address you provided to us, unless we do not have your email address.

It is your responsibility to check back here periodically and review this Privacy Policy. It governs your use of the Services, and you are responsible for reading and understanding it. You are bound by any changes to the Privacy Policy when you use the Services after such changes have been posted. Use of any Personal Information that we collect now is and will be subject to the Privacy Policy in effect at the time such Personal Information is used.

What Personal Information do we collect?

Information You Provide To Us

We collect and store any Personal Information you knowingly provide to us.

Through the registration process and/or through your account settings, we may collect Personal Information such as your:

  • name
  • email address
  • age verification information

 

We also collect Personal Information that you provide to us through your use of the Services, including when you activate and use the App to track a recycling deposit, or when you register to participate in a Contest. [This includes:

  • The images of recycling bins you upload each time you log a recycling activity, so we can verify that the recycling bin is an Eligible Recycling Bin (as that term is defined in the Contest Rules).

  • Your geolocation information each time you log a recycling activity so we can verify you are located in Manitoba.

  • The beverage container bar codes you scan when logging a recycling activity (including the number of times each bar code was scanned), so we can verify that the beverage container is an Eligible Beverage Container (as that term is defined in the Contest Rules).

 

As described above, the Services include features that use precise geolocation data, including GPS signals, device sensors, Wi-Fi access points, and cell tower IDs. We may also derive your approximate location from your IP address. We collect this type of data if you grant us access to your location. You can always remove our access to your geolocation data using your mobile device settings. If you remove our access to this data, some on the features of the Services may no longer function.

If you choose to share any information from your user account to a third-party platform, including to a social media platform through any links available on the App, that information will be subject to the privacy policies and practices of that third party, not those of the CBCRA.

Information Collected Automatically

Whenever you interact with our Services through the App, we may automatically receive and record information on logs and databases from the App, your browser, or device(s).

Information that is collected automatically when you interact with the Services may include your:

  • operating system information
  • cookie information
  • Internet Protocol (IP) address
  • domain name
  • click-activity
  • geolocation data and/or a date and time stamp relating to your use of the Services, which is provided to us through the GPS sensor tracking function on your device


“Cookies” are identifiers we transfer to your device that allow us to recognize your browser, App or device and tell us how and when various pages and features in our Services are visited or used and by how many people. You may be able to change the preferences on your browser or device to prevent or limit your device’s acceptance of cookies, but this may limit some of the App’s functionalities. In addition, our third party business partners (discussed below), may also use web beacons, or transmit cookies to and read cookies from your browser, App or device when you visit or use our Services. If you click on a link to a third party website or service (for example, an in-App link that directs you to a third party social media platform), such third party may also transmit cookies to you. This Privacy Policy does not cover the use of cookies by any third parties.

We may deliver a file to you through the Services (known as a “web beacon”) from an ad network. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Because your web browser must request these advertisements and web beacons from the ad network’s servers, these companies can view, edit, or set their own cookies, just as if you had requested a web page from their site.

Although we would like to honor browsers set with do not track (“DNT”) signals, at this time, our Services do not respond to DNT signals or other mechanisms that might enable users to opt out of tracking on our Services. For more information about DNT, please visit: allaboutdnt.com.

How do we use your Personal Information?

We use your Personal Information to:

  • identify you while you are using the Services
  • confirm you are accessing the Services from within Manitoba, including by using your geolocation data when you are using the Services
  • identify eligible recycling bins when you register a recycling activity
  • verify eligible beverage containers when you register a recycling activity
  • validate Contest-winning recycling deposits
  • manage Contest draws
  • manage allocation of Contest prizes and communication with winners
  • provide you with notices about your account or about changes to our App or any products or services we offer or provide though it
  • allow you to participate in interactive features through the App
  • improve the Services and User experience
  • provide user support when you contact us with an inquiry
  • understand your preferences to help us improve our Services, including by making them more user-friendly and efficient

 

We may anonymize and aggregate your Personal Information so that you cannot be individually identified and then use that information to analyze and better understand the recycling habits of users generally. For example, such anonymized and aggregated data may be used to determine the number of beverage containers recycled in Winnipeg on a given day, the frequency of recycling deposits made in public bins and private bins, and which types of beverage containers are being recycled.

We may also use your Personal Information for any other purpose with your consent.

For users participating in Contests, by participating in a Contest, all entrants consent to the use of their account information (including their name, mailing address, phone number and email address), and information about their winning recycling deposit (including geolocation information and the uploaded image) for the administration of the Contest.

Disclosure of your Personal Information

We do not sell your Personal Information to third parties. We may share your Personal Information with others for the following reasons.

Sharing as required by law or to protect against violations

Regardless of any choices you make regarding your Personal Information in accordance with this Privacy Policy, we may disclose Personal Information if we believe in good faith that such disclosure is necessary: (a) in connection with any legal investigation; (b) to comply with relevant laws or to respond to subpoenas or warrants served on us; (c) to protect or defend our rights, our property or users of the Services; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, our Terms of Use, or the Contest Rules.

Sharing with business partners to help us provide the Services

We may also disclose or transfer your Personal Information to contractors, service providers, and other third parties we use to support our business. Any time we disclose or transfer your Personal Information to a third-party, we contractually require that third-party to use your Personal Information solely for the purposes identified in this Privacy Policy, and to implement appropriate privacy and security measures to protect your Personal Information in a way that is consistent with this Privacy Policy.

Sharing with third-parties in the event of a major change to our company

We may also share some or all of your Personal Information in connection with or during negotiation of any merger, financing, acquisition or dissolution transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of insolvency, bankruptcy, or receivership, Personal Information may also be transferred to a business asset. If another company acquires our company, business, or assets, that company may possess the Personal Information collected by us and will assume the rights and obligations regarding your Personal Information as described in this Privacy Policy.

Sharing anonymized and/or aggregate information

We may provide anonymized and aggregated information to our business partners, who may use such information to understand how often and in what ways people use our Services. However, except as described below, we do not disclose anonymized or aggregated information to any business partner in a manner that would identify you personally, as an individual.

Security of your Personal Information

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.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to the App, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

We endeavor to protect the privacy of your account and other Personal Information we hold in our records, but we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the App.

If we reasonably believe a breach of security has affected your Personal Information that is under our control, and such breach creates a real risk of significant harm, we will investigate the situation and, where appropriate, notify you. We will take all other steps which we believe are appropriate or legally required.

How long do we keep your Personal Information?

We retain your Personal Information only as long as we require it to provide the Services to you and to maintain an appropriate historical record of our relationship with you. If there are legal or business requirements relating to the period of time which we must retain your Personal Information, we comply with those requirements.

What if you want to limit the use of your Personal Information?

Most of the Personal Information we collect is necessary for the operation the Services.

If you do not want us to use or disclose your Personal Information in other particular ways, please contact us using the contact information at the bottom of this Privacy Policy and we will be pleased to discuss with you how we can limit collection, use or disclosure of your Personal Information.

You may request access and changes to your Personal Information

Through your account and Service settings, you may be able to access, and, in some cases, edit or delete the following information you’ve provided to us, which may include:

  • name
  • log-in information
  • email address
  • mobile phone number
  • postal code

The information you can view, update, and delete may change as the Services change.

You have the right to access the Personal Information that we have about you and to request that Personal Information which you believe to be inaccurate be corrected. If you wish to access or correct your Personal Information, you should contact our Privacy Officer using contact details at the bottom of this Privacy Policy.

If you want to withdraw your consent to our use of your Personal Information you may send us an email to request the deletion of any Personal Information that we may have collected about you. We cannot delete your Personal Information except by also deleting your user account. Please note that if you withdraw your consent we may not be able to provide you with the Services. We will explain the impact to you at the time to help you with your decision.

Uninstall the Mobile Applications

You can stop all collection of information by the App by uninstalling it from your mobile device. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network.

What about children?

Use of or access to the any of the Services by users under the age of 18 is strictly prohibited. If you are under 18, please do not attempt to register for the Services or send any Personal Information about yourself to us. If we learn that we have collected Personal Information from a child under 18, we will delete such Personal Information. If you believe a child under 18 may have provided us Personal Information, please contact us immediately using the contact information at the bottom of this Privacy Policy.

Questions? Concerns?

If you have any questions or concerns about this Privacy Policy, or wish to withdraw your consent, please contact our Privacy Officer and we will try to address your concerns:

Title:    Privacy Officer

Email: privacypolicy@cbcra-acrcb.org