In-Effect Date: July 10, 2018
The Sites are intended for the use of our customers and users in Canada only. You may not use the Sites from another country. If you use the Sites from another country, you agree that only the laws of Canada will apply to your use and that we will under no circumstances be liable for, and you will hold us harmless against the application of the laws of any other country.
Types of Information Collected
Depending on the circumstances, we may collect different types of personal information about you, including the following:
- your name;
- your address;
- your date of birth;
- your email address;
- your phone number;
- your use of the FLO Network, such as your power consumption, the date of use, your geolocation and other similar information;
- your electric vehicle model;
- identifiers such as cookies, IP addresses, and mobile device IDs that recognize individuals over time and across different websites or online services, where those identifiers can be reasonably linked to an identifiable individual; and
- details about problems using the FLO Network you may have experienced.
We may solicit your input on your experience using the FLO Network or navigating the Sites.
If you communicate with one of our representatives by phone, the conversation may be recorded in order to assess the quality of the service, to train our employees or to protect both parties in case of disagreement. You will be notified of such recording in advance and may refuse it.
You may disable cookies on your computer. Most browsers are initially set up to accept cookies; however, the “help” feature of the menu bar on most browsers will tell you how to manage cookies and/or how to disable them completely.
Please be advised that disabling cookies may affect user functionality. For instance, visitors who have disabled cookie processing will no longer be able to enjoy all functionalities related to the management of their user account.
We keep standard web logs that record data about all visitors to the Sites. These logs do not contain personally-identifiable information and may consist of:
- the Internet domain from which you access the Sites;
- the location from which you access the Sites• the type of browser and operating system you use;
- the date and time you visited the Sites;
- the pages you viewed on the Sites; and
- the address of the websites from which you linked to the Sites.
We also may have to record your IP address when you visit the Sites. When you surf the Internet, your computer is automatically assigned an IP address via an Internet protocol. Your IP address is either static or dynamic; a static IP address may allow for you to be identified; while a dynamic IP address does not usually allow for it.
Information Through Mobile Devices
When you access the Sites or the FLO Network through your mobile telephone or other mobile devices (“Mobile Device”), we may collect: (i) Mobile Device type and manufacturer; (ii) mobile carrier; (iii) Mobile Device identifiers (“Device ID”); (iv) telephone number; (v) Internet Protocol address; (vi) geographic location/country/zip code; (vii) platform version; (viii) installation, navigation, access, interaction, impression and engagement information; (ix) network connection type; (x) browser type; (xi) Mac address; (xii) iOS advertiser ID; and (xiii) such other information you voluntarily provide to us. In addition, we may collect information you provide when you sign up to have Short Message Service notifications sent directly to your Mobile Device.
The Sites are not intended for children under the age of 17. If you are under 17, please do not provide personal information to us of any kind whatsoever. If a child of less than 17 provides us with personal information, a parent or guardian of that child may contact us to have this information deleted from our records. If you believe that we may hold information from a child under the age of 17, please notify us though our Privacy Officer by e-mail at firstname.lastname@example.org.
Use of Information
We use the information we collect about you mainly for the following purposes:
- Administering the Sites and making them available to you;
- Allowing you to buy our products and services online;
- Allowing you to access the FLO Network and networks with which we have roaming agreements and to use the charging services they offer;
- Billing you for your charging activities on the FLO Network and networks with which we have roaming agreements;
- Detecting and preventing threats to computer or FLO Network security;• Developing and marketing our brand image, products and charging services, promotions and advertising;
- Communicating with you about technical notices, product and service upgrades, security alerts and support—because this information is important to your interaction with FLO, you may not opt out of receiving these communications while you still have an account with us;
- Verifying your identity and the veracity of any requests if you contact us;
- Responding to your requests, complaints, comments and questions, including helping you find alternative charging locations near you, if necessary;
- If you enter into a sweepstake, contest, or similar promotion, we may use the information you provide to administer those programs; and
- From time to time, any other purpose authorized or required by applicable law.
We also use the information we collect about you to generate statistics, gather information, and measure activity on the Sites and on the FLO Network. When we compile information for these statistical purposes, your personal information is not individually identifiable. Rather, it forms part of a whole made up of data from all the users of charging stations.
Sharing of Information
Partners and Suppliers
FLO may share information related to your use of the Sites and the FLO Network (i) with the owners and the hosts of our charging stations, and with our service providers and entities with which we run joint programs or offers, such as electricity suppliers, in order to improve or to continue to offer the charging services and to provide services related to programs you have chosen to participate in involving our service providers and entities with which we run joint programs or offers.
Within FLO, we limit access to your personal information to authorized personnel in compliance with applicable law.
We may also share information with third parties, specifically financial and legal advisors, as part of a sale or assignment of our business, for audit purposes or for other financial transactions, including, but not limited to, credit transactions.
In the event we combine with another company in the future through a corporate merger, sale, acquisition, liquidation or other similar process, your personal information may be transferred with the business or a part of it, or may be sold as an asset of the business, to the successor organization in such transaction. If material changes to our privacy practices will occur as a result of such transaction, you will be notified via prominent notice in our Sites of any change in ownership or uses of your personal information, as well as choices you may have regarding your personal information.
We may share with third parties some non-personally identifiable information and aggregated non-personally identifiable information, for example, the number of customers located in a certain geographic area or the number of hours in a day customers with an electric vehicle use electric vehicle chargers.
Safekeeping of Information
No method of transmission over the Internet, or method of electronic storage is ever completely secure. There is always a risk that the information you are sending us may be lost, intercepted, hacked or misused. Therefore, we encourage you to take special care in deciding what personal information you provide to us as we cannot guarantee its absolute security.
Storage of Information
All personal information will be safeguarded in a confidential manner in compliance with the privacy laws of the jurisdictions where we do business. We employ reasonable administrative, technical and physical safeguards to protect your personal information from loss, theft and unauthorized access, use, modification and destruction.
Access to your personal Information
You have a right, under the law, to obtain access to your personal information and to request that it be corrected if the personal information is inaccurate, out of date, incomplete or ambiguous, or if the collection, release or keeping of the information is not authorized by law. If you notice any errors or inaccuracies, please let us know and we will make the necessary corrections. Subject to our retention rights described below, you may also request to have your personal information deleted. Any request for access to, or correction or deletion of your personal information and any notice shall be directed by e-mail to FLO’s Privacy Officer: email@example.com.
Your personal information is kept as long as required for the purposes for which it was collected or for the purposes of compliance with our legal and regulatory obligations. When the information is no longer necessary, it is destroyed. When destroying documents and data, we follow strict procedures and ensure that only authorized personnel have access to them.In addition, we will provide notice to you of any breach of security, confidentiality or unauthorized release of personal or private data in accordance with applicable laws, rules and regulations.
Customized Social Media Ads
FLO partners with third-party social media platforms, such as Facebook, to show you customized advertisements. To offer such ads, we may convert your email address, telephone number or other contact information you have provided to us into a unique value which can be matched to your social media profile by our partners, such as Facebook or other social media platforms. While FLO does not provide any personal information to these platforms, these platforms may gain insights about individuals and help us in providing interest-based advertising. Please visit Facebook for information on Facebook’s advertising and privacy policies (https://www.facebook.com/about/privacy/), and visit any other social media platform you use for information on their policies.
Your Choices with Respect to Interest-Based Advertising
You have a choice whether or not to accept the use of certain cookies by using the “help” feature of your Internet browser.
You can opt-out of network advertising programs here:
- Digital Advertising Alliance of Canada opt-out page: http://youradchoices.ca/understanding-online-advertising,
- NAI opt-out page: http://www.networkadvertising.org/managing/opt_out.asp, and
- Ad Choices opt-out page: http://www.aboutads.info/choices/
You can opt-out of customized social media ads by adjusting your social media settings (for instance, you can manage your settings via your Facebook profile). You can also unsubscribe from mailing lists by using the links included in the advertisements.
Do Not Track
We do not respond to DNT (Do Not Track) signals.
Please note that if you opt-out you may still receive online advertising from FLO or from other websites or applications. However, these advertisements will not be displayed to you based on your interests.
© 2018. Services FLO Inc. All rights reserved.FLO.PRIVACY.POLICY.FR.09.2018.v1