Privacy commitment

Privacy Commitment

At Mobile Klinik, we respect our customers’ privacy and take great care to safeguard personal information. As part of our ongoing commitment to putting customers first, we have a long-standing policy of protecting privacy in all of our business operations.

We believe that an important part of protecting privacy is to be clear about how we handle customers’ personal information, and to make information about our approach easily accessible.

We have developed this Privacy Commitment to provide you with specific details about our privacy practices and to set out the general principles that govern the collection, use and disclosure of our customers’ personal information. 1

We have learned from our customers that sometimes you just want the big picture, while other times you may want more details or examples of how a policy or process works. Importantly, our Privacy Commitment reflects the requirements of Canada’s applicable privacy legislation, including the Personal Information Protection and Electronic Documents Act, and our own continuing commitment to customer privacy. The bottom line is that we want you to understand the purposes for which we collect, use and disclose personal information about our customers. The following is a summary of our privacy practices.

Definitions

Affiliates – refer to entities, businesses and/or divisions including but not limited to, TELUS Communications Inc. and its subsidiary companies, as they may exist from time to time, including those subsidiaries or divisions that carry on business under the names TELUS, TELUS Communications, TELUS Mobility, TELUS Québec, TELUS Retail Ltd., Koodo, and Public Mobile. Mobile Klinik is a part of the TELUS family. For more information about these Affiliates’ privacy practices and policies click here.

Customer – refers to an individual who uses, or expresses interest to use, Mobile Klinik’s products or services.

Mobile Klinik – In this Privacy Commitment, the words “we”, “us”, “our” or “Mobile Klinik” refer to Mobile Service Center Canada Limited, doing business as Mobile Klinik Professional Smartphone Repair, and its subsidiary companies, as they may exist from time to time. The words “we” and “Mobile Klinik” do not include independent dealers, franchisees and distributors of Mobile Klinik or our Affiliates’ products and services.

Personal information – refers to any information about an identifiable individual, other than the name, title or business address (including business email address) or business telephone or fax numbers of an employee of an organization. Personal information does not include de-identified or aggregated information that cannot be reasonably associated with a specific individual. Information about customers who are sole proprietors or partners is considered to be “personal information” if it is information about the individuals themselves, as distinct from information about their businesses. The latter is protected by other Mobile Klinik policies and practices and through contractual business arrangements.

Why we collect personal information

Mobile Klinik collects certain information about you and your use of our products and services, or your application for, or interest in, our products and services. Unless required by law or for exceptions set out in applicable legislation, Mobile Klinik shall not use or disclose for any new (not previously-identified) purpose personal information that has been collected without first identifying the new purpose and obtaining appropriate consent of the customer.

Mobile Klinik will require customers to consent to the collection, use or disclosure of personal information as a condition of the supply of a product or service if such collection, use or disclosure is required to fulfill the identified purposes. In general, the use of products and services by a customer, constitutes implied consent for Mobile Klinik to collect, use and disclose personal information for all identified purposes.

We respect your privacy, which is why we collect personal information only for the following purposes:

To establish and maintain a responsible commercial relationship with you and to provide ongoing service.

Here are some examples of what we mean by this:

• When you complete a repair, trade-in a device, purchase a Certified Pre-Owned phone, or transact with us, we generally set up a customer profile and collect information such as name, address, preferred language, phone number, and email address.
• In order to confirm your identity and/or allow our supplier or Affiliates to conduct a credit check, we may also ask for acceptable identification or identifying information.
• In order to complete a repair, we may ask for your mobile device password. 2
• We also collect and use some personal information to confirm your identity when you contact us. For example, when you call us, we will ask to confirm some personal information to verify it’s actually you.
• If you use a Mobile Klinik mobile application (app) or web service, we collect information that is reasonably necessary to authenticate you and provide the service.
• For billing purposes, we collect records of the services you use, as well as payment information to complete your transaction, or set up pre-authorized payments (if applicable). If you have entered into a financing agreement for your purchase or repair with one of our suppliers, partners or Affiliates, your payment information will be used to set up pre-authorized payments and will be governed by the privacy policy of that supplier, partner or affiliate.
• If you use any of our remote repair services (i.e., mail-in repair, Onsite Repair Unit), we collect your address and other relevant information in order to provide those services to you.

To understand your needs and preferences.

Here are some examples of what we mean by this:

• We maintain a record of the products and services you receive from us, and we may collect additional information about patterns associated with those products and services.
• Some of the data we collect or use for this purpose includes your wireless device information, such as telephone number, SIM card number, mobile carrier, operating system, network type, device manufacturer, model and make, device serial number, downloaded diagnostic results, or other applications and their respective settings and IMEI serial number.
• We may also collect additional information to better meet your preferences, including details of the products and services you receive from us, such as the type of repair completed, the brand, make and model of the certified pre-owned device purchased.
• We may collect or infer information about you or your preferences for particular products, services or lifestyle activities from information you provide us about yourself when you tell us your preferences, or we may collect such information from other sources authorized to disclose it.

To develop, enhance, market or provide products and services.

Here are some examples of what we mean by this:

• From time to time, we, or our Affiliates may review and analyze your use of our products and services to help us provide better product recommendations and special offers that we think will interest you.
• We may analyze your use of our products and services to better understand your preferences, and to help us develop or enhance our products and services. For example, if we see that you completed a repair quote or phone repair, we may send you information on or an offer for a Certified Pre-Owned phone.
• We, or our Affiliates may note that you purchased a Certified Pre-Owned phone and may offer you a discount on an Accessory or Extended Warranty or we may send you a special activation offer with our Affiliates.
• We might recommend a new service or product from Mobile Klinik or our Affiliates that we think you’ll enjoy based on your existing transactions.

We note that our customers who do not wish to receive these types of recommendations or offers may choose to be removed from our marketing lists at any time.

To manage and develop our business and operations.

Here are some examples of what we mean by this:

• We may collect personal information to help us manage our day-to-day operations, and to manage our business, including securing it and planning for future growth.
  • We may use traffic counters to analyze how many customers visit our stores or use the onsite repair service at what times of the day to help us plan new store locations, team members scheduling and to develop our business and operations.
• We may use video surveillance to monitor and/or record the activity that occurs in and around Mobile Klinik stores, premises or to manage our business and operations. This information is used for security and investigation purposes to protect us from theft, vandalism or damage to our property and, most importantly, to protect you and our team members.
• We, or our suppliers, may monitor payment activity to detect and prevent fraud to protect both our customers and our business.
• We may record interactions, such as telephone calls or chats, to or from Mobile Klinik service representatives for quality assurance and training purposes; our systems may also conduct real-time analytics on such interactions to identify trends and patterns to help us serve you better. In some cases, we may use conversational artificial intelligence (chatbots) to help you expedite your interactions with Mobile Klinik.
• We collect information about visits to our websites (such as mobileklinik.ca) to optimize our web properties, and for security purposes.

To meet legal and regulatory requirements.

Here are some examples of what we mean by this:

• We may collect or preserve information in response to a court order.
• We need to collect certain information to comply with statutory obligations, including our tax reporting obligations.

When we share personal information

We take great care with what information we share, and why. There are circumstances where we share some personal information about our customers:

To facilitate and improve the provision of products and services to you.

Here are examples of what we mean by this. We may share personal information with:

• a person seeking information as an agent of a customer, such as a customer’s legal representative, if we are satisfied that the person is authorized to receive the information;
• We, or our suppliers and Affiliates may also share your personal information with collection agencies to collect an account if your account has been referred for collection;
• Our Affiliates help us serve our customers better and to provide customers with services from different parts of the company.

To enable our suppliers, service providers, partners and Affiliates to help us serve you better.

We may share information with our suppliers, service providers, partners, Affiliates, agents or other organizations or individuals contracted to Mobile Klinik to perform services or functions on our behalf where they require the information to assist us in serving you. We strive to minimize the amount of personal information that we share with our suppliers, service providers, partners and Affiliates; we share the information reasonably necessary to achieve the stated purpose, and require that it only be used for that purpose.

Examples of what we mean by suppliers, service providers, partners, or Affiliates include organizations that:

• Conduct research on our behalf, such as customer satisfaction surveys;
• Perform data processing on our behalf, such as printing customer statements;
• Provide diagnostic data on customers’ devices;
• Manufacture equipment or parts, or provide warranties on customers’ devices;
• Provide extended warranties on or equipment repair services to customers’ devices;
• Administer special programs with us, such as a rewards program.

When data crosses borders.

Personal information collected by Mobile Klinik will be stored and processed in Canada or other countries. In either case, the information is protected with appropriate security safeguards, but may be available to foreign government agencies under applicable law. In particular, your personal information may be stored in the cloud, which may include transfers of data outside of Canada. Where appropriate, we use de-identification and other means to protect and minimize the amount of personal information we transfer.

For emergency purposes.

We may share information with a public authority or agent of a public authority if, in the reasonable judgment of Mobile Klinik, it appears that there is imminent danger to the life, health or security of an individual which could be avoided or minimized by disclosure of the information.

Where required by law or applicable regulation.

We share customer personal information with law enforcement or other government agencies if we are required to do so to meet legal and regulatory requirements; for example, if Mobile Klinik is required to provide records to law enforcement in response to a valid court order.

Note to our customers

Our suppliers, partners and Affiliates may offer payment solutions (such as purchase financing) to you. If you choose to apply for these third party services, such supplier, partner or affiliate may collect personal information in order to share that personal information with credit bureaus. The use, collection and disclosure of your personal information in these cases will be governed by the privacy policy of said supplier, partner or affiliate.

Some of the ways we respect your privacy

• Mobile Klinik has appointed a Privacy Officer responsible for maintaining an accountable privacy management program specifically designed to protect your privacy, and for setting policies and procedures to earn and maintain your trust in our data handling practices.
• We maintain a robust information security governance program to protect your personal information with appropriate security safeguards. Our safeguards include administrative, physical and technical security controls. We protect the privacy of your personal information through contractual and other means to provide comparable levels of protection when we are working with other organizations.
• We may de-identify personal information for a variety of reasons, including to safeguard it, or where de-identified information will serve the purposes for retaining the information. We may de-identify data prior to conducting analytics that don’t require personal information.
• We strive to keep your personal information as accurate and up-to-date as is reasonably necessary for the identified purposes.
• We respond in a timely manner to your requests for access to your personal information. In certain situations, we may not be able to provide access to all the personal information that we hold about a customer. For example, we may not provide access to information if doing so would likely reveal personal information about a third party or could reasonably be expected to threaten the life or security of another individual. Also, Mobile Klinik may not provide access to information if disclosure would reveal confidential commercial information, if the information is protected by solicitor – client privilege, or, in civil law, by the professional secrecy of lawyers and notaries, if the information was generated in the course of a formal dispute resolution process, or if the information was collected in relation to the investigation of a breach of an agreement or a contravention of a federal or provincial law. If access to personal information cannot be provided, Mobile Klinik shall provide the reasons for denying access upon request. In general, the exceptions above do not apply if the individual needs the information because an individual’s life, health or security is threatened.
• We keep personal information only as long as reasonably necessary for the purposes we have identified to you, or as required by law. We shall develop guidelines and implement procedures and controls for the retention and destruction of records containing personal information
• We take privacy and security training and awareness seriously, and we use a variety of different methods to assist our Mobile Klinik team members in respecting and protecting your privacy.
• Unless you provide your express consent, Mobile Klinik does not disclose your personal information to marketers of third-party products or services to enable targeted advertising, or for any other purpose. For clarity, Mobile Klinik may disclose personal information to our Affiliates, in accordance with this privacy commitment.
• We use cookies in a limited manner, and only for purposes consistent with this Commitment. For more information, please refer to our Cookies Notice in our Website User Terms.
• Privacy legislation generally sets out certain circumstances under which organizations may collect, use or disclose personal information without consent. Examples include emergency circumstances or the investigation of a contravention of laws. Other than under such specified circumstances, Mobile Klinik will not collect, use or disclose your personal information for any purpose other than those identified in this Commitment, our agreement with you, or Service Terms, except with your consent.
• A customer shall be able to address a challenge concerning compliance with Mobile Klinik’s privacy practices to the Privacy Officer accountable for Mobile Klinik’s compliance with the Mobile Klinik Privacy Commitment.
• Mobile Klinik will continue to review this Commitment to ensure it is relevant, remains current with changing technologies and laws, and continues to meet your evolving needs.

Choices we offer you

We rely on your consent to continue to collect, use and disclose your personal information for the purposes we have identified to you. However, we want you to know that you do have choices and can refuse or withdraw your consent as follows:

• You may have your name removed from one or more of our marketing lists, such as our telephone, mail or email marketing lists. We use these lists to inform you of relevant products, services and special offers that may be of benefit to you.
• You may refuse to provide personal information to us. You may also withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice. However, in either case, this may limit our ability to serve you and may force us to refuse some or all of the services you may receive from us.
• For further information about the above options, please contact us at 1-866-210-1070.

Unless you tell us otherwise, we will assume that we have your consent to continue to collect, use and disclose your personal information for the purposes we have identified to you.

You may choose to unlink your devices that may be linked through our participation in a co-op designed to help us deliver consistent advertising across all of the devices you use when you access our website or use our apps. To learn more about cross-device linking or to unlink your devices, visit our Cookies Notice.

Questions?

We want you to be comfortable with how we protect your privacy. If you have questions that are not addressed in this Commitment, please call us at 1-866-210-1070 or email privacy@mobileklinik.ca.

Legal Footnotes

1. The Mobile Klinik Privacy Commitment does not limit the collection, use or disclosure by Mobile Klinik of information that is publicly available. This includes: (a) a customer’s name, address, telephone number, and email address, when listed in a directory or available through directory assistance; and (b) other information about the customer that is publicly available and is specified by regulation pursuant to the Personal Information Protection and Electronic Documents Act or other applicable legislation. The Mobile Klinik Privacy Commitment does not apply to personal information created by, or collected from or on behalf of Mobile Klinik’s business customers and their employees or contractors receiving Mobile Klinik services under corporate customer agreements. However, such information is protected by other Mobile Klinik policies and practices and through contractual arrangements. The Mobile Klinik privacy practices described in this Commitment are subject to the provisions of all applicable Canadian privacy legislation and regulations.
2. If you are unsure whether that you are being contacted by Mobile Klinik, please end the communication, and then contact Mobile Klinik using the contact information on https://mobileklinik.ca/contact-us/, or the contact information on your confirmation receipt for mail-in repairs. To learn more on how to protect the privacy and security of your information, check out the resources on the TELUS website, here.