INSTA CONNECT INC.
PRIVACY POLICY
Wag Buddy App
Date: June 23, 2023
PRIVACY POLICY OVERVIEW
This Privacy Policy establishes rules to govern the collection, use and disclosure of personal information
collected by InstaConnect Inc. (the “Company”) in the course of business, in compliance with federal and
provincial privacy laws including the Canada Personal Information Protection and Electronic Documents Act
(PIPEDA), Alberta’s Personal Information Protection Act, British Columbia’s Personal Information Protection
Act and Quebec’s Act respecting the protection of personal information in the private sector.
This Privacy Policy applies to all individuals whose personal information the Company collects, uses or
discloses in the course of doing business. It is our policy to only disclose your personal information as required
or authorized by law or as otherwise set out in this policy.
We reserve the right to change this policy from time to time as industry practice, the law, and our procedures in
this area may change from time to time.
By using our Services, you are accepting the practices described in this Privacy Policy.
PERSONAL INFORMATION
For the purposes of this Privacy Policy, “personal information” means information about an identifiable
individual. Where this Privacy Policy states that a list of items is “including”, the lists so described are meant to
be examples and not exhaustive or exclusive.
This Privacy Policy applies to all personal information that is collected, used or disclosed by the Company. The
Company has designated a Privacy Officer to be accountable for the operation of this Privacy Policy. Individuals
may question or report any privacy concerns, breaches, violations or compliance issues to the Company's
Privacy Officer at the address indicated below.
If the policies and procedures outlined in this document do not address a specific situation, individuals are
advised to contact the Company's Privacy Officer for guidance or clarification.
PERSONAL INFORMATION WE COLLECT
The Company collects and uses only the personal information that we need for opening Wag Buddy App
Account for use of the Wag Buddy App and operating our business. Generally, the Company collects the
following personal information from individuals for the various purposes set out below:
(i) Dog Owner Name (User Name)
(ii) Dog Owner Profile Picture
(iii) Dog Name
(iv) Dog Profile Picture
In order to register as a user of Wag Buddy, you will be asked to sign in using a social login (Facebook or
Google). Social Login information is processed by Facebook and Google Servers.
The Company collects, uses and discloses personal information for the following purposes:
To confirm your identity and personal information
To manage the Company's business and operations, including customer relationships and matters, and
To meet legal and regulatory requirements;
Inform individuals about the Company's products and services that we believe may be of interest to them.
Better understand an individual’s interests in our products and services.
Deliver, develop, enhance or improve products and services.
Meet regulatory requirements
Conduct market research
To enforce our legal relationship with you
Communicate with you to respond to your comments and questions, provide customer support, send technical
notes, service messages, security alerts, promotional messages, and other messages for various purposes.
We normally collect information directly from you. We may collect your information from other persons with
your consent or as authorized by law. Before or at the time of collecting personal information, we identify the
purposes for which we are collecting the information. We do not provide this notification when personal
information is volunteered for an obvious purpose. If we wish to use or disclose your information for a new
purpose not included in this policy, we will notify you and seek your consent.
We also receive and send data from our servers and from your browser when you use our application, or visit our
website, including your IP address, the time and information about the page you requested and the website
through which you were linked to our site, if any. We may use technologies in a variety of ways, including the
following: keeping count of return visits to our application or site; accumulating and reporting anonymous,
aggregate (data collected in mass), statistical information on application or website usage; and determining
which features users like best.
Finally, your Internet browser has a feature called "cookies," which stores small amounts of data on your
computer about your visit to our site. Cookies tell us nothing about who you are, however, unless you
specifically give us personal information. You do not need to have cookies turned on to visit our website. You
may also elect not to allow cookies to be collected by selecting certain options on your browser.
CONSENT
Ordinarily we ask for consent to collect, use or disclose personal information, except in specific circumstances
where collection, use or disclosure without consent is authorized or required by law. We may assume your
consent in cases where you volunteer information for an obvious purpose.
You may withdraw consent to the use and disclosure of personal information at any time, unless the personal
information is necessary for us to fulfil our reasonable business or legal obligations. We will respect your
decision, but we may not be able to provide you with certain products and services if we do not have the
necessary personal information.
COLLECTION OF PERSONAL INFORMATION
The purpose for collecting personal information is set out in this policy. Any necessary consent shall be obtained
before personal information is collected, used or disclosed.
We ask for your express consent for some purposes and may not be able to provide certain services if you are
unwilling to provide consent to the collection, use or disclosure of certain personal information. Where express
consent is needed, we will normally ask clients to provide their consent orally (in person, by telephone), in
writing (by signing a consent form), or electronically (by clicking a button).
We ask for your express consent for some purposes and may not be able to provide certain services if you are
unwilling to provide consent to the collection, use or disclosure of certain personal information. Where express
consent is needed, we will normally ask clients to provide their consent electronically by clicking a button. We
may rely on “opt-out” consent for certain types of information.
Personal information collected by the Company or on behalf of the Company will be sent to the Company’s head
office located in Calgary, Alberta and will be subject to the laws of Canada.
Please note that we may use cloud-based services to store information.. Where personal information is stored or
processed outside of Canada, it is subject to the laws of that foreign jurisdiction, and may be accessible to that
jurisdiction’s governments, courts or law enforcement or regulatory agencies.
SHARING OF PERSONAL INFORMATION
The Company will NOT sell, rent or trade your personal information to any third party. Your information may
be made available by the Company to third-parties or service providers only to fulfill the purposes for which it
has been collected or as set forth in this Privacy Policy. As stated above, we will NOT sell, rent or trade your
personal information to any third party. However, we may share your personal information when authorized by
law or as follows:
Other Wag Buddy Users. As a registered user of Wag Buddy, your and your pet's name and profile picture will
be viewable by other users of the Services.
Third party or affiliated service providers. We may hire service providers, which may be affiliates, to perform
services on our behalf. We provide them with a limited amount of information which is necessary in order for
them to provide the services required. They are prohibited from using the information for purposes other than to
facilitate and carry out the services they have been engaged to provide. These service providers are not permitted
to disclose this information to others. The Company will strive to protect personal information disclosed to third
parties by contractual agreements requiring that those third parties adhere to confidentiality and adequate
security procedures.
As permitted or required by law. From time to time, the Company may be compelled to disclose personal
information in response to a law, regulation, court order, subpoena, valid demand, search warrant, government
investigation or other legally valid request or enquiry. In these circumstances, the Company will protect the
interests of its customers by making reasonable efforts to ensure that orders or demands comply with the laws
under which they were issued, that it discloses only the personal information that is legally required and nothing
more, and that it does not comply with casual requests for personal information from government or law
enforcement authorities. We may also disclose information to our accountants, auditors, agents and lawyers in
connection with the enforcement or protection of our legal rights. We also reserve the right to report to law
enforcement agencies any activities that we, in good faith, believe to be unlawful or to law enforcement and
emergency services providers, in an emergency or where required or permitted by law. We may release certain
personal information when we have reasonable grounds to believe that such release is reasonably necessary to
protect the rights, property and safety of others and ourselves, in accordance with or as authorized by law.
Business transaction. We may disclose personal information to a third party in connection with a sale or
transfer of business or assets, an amalgamation, re-organization or financing of parts of our business. However,
in the event the transaction is completed, your personal information will remain protected by applicable privacy
laws. In the event the transaction is not completed, we will require the other party not to use or disclose your
personal information in any manner whatsoever and to completely delete such information.
OBTAINING ACCESS TO PERSONAL INFORMATION
Upon request received by the Company in writing, individuals shall be informed of the existence, use, and
disclosure of their personal information records and shall be given access to that information. Requests to access
personal information held by the Company should be directed to the Company's Privacy Officer.
Requests must be made in writing or by e-mail. Individuals may be required to verify their identity in order to
access their personal information. Any such documentation provided shall be used for verification purposes only.
A fee for reasonable costs incurred may be charged when responding to more complex requests, if authorized by
law. The individual will be informed of the applicable fee.
Requested information will be provided in a form that is generally understandable.
The Company will be as specific as possible when describing third parties to whom it has disclosed personal
information about an individual.
Individuals are permitted either to view the original record, or to request a copy, subject to limitations as
permitted or required by law. To preserve the integrity of the record and ensure that documents are not removed
from the Company, individuals wishing to view an original record will do so at the Company's head office and
under the supervision of designated Company personnel.
LIMITATION TO ACCESS
The Company will only refuse access to information about you in those circumstances permitted or required by
applicable privacy legislation.
In the event that the Company refuses to provide access to information, it will provide you with the reasons for
its refusal upon request. Exceptions may include information that contains references to or opinions of other
individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons, or
information that is subject to solicitor-client or litigation privilege. The Company will respond to your requests
for access in accordance with applicable privacy legislation.
MAINTENANCE OF PERSONAL INFORMATION
Personal information shall be kept as accurate, complete, and up-to-date as necessary for the purposes for which
it is to be used.
Individuals have the right to challenge the accuracy and completeness of the personal information that is
maintained by the Company and have it amended as appropriate.
Individuals seeking a correction or amendment to their personal information should direct their requests in
writing to the Company's Privacy Officer.
All formal requests to amend personal information must be accompanied by appropriate supporting
documentation. The Company’s Privacy Officer will manage any exceptions. The amended information will be
transmitted to third parties, as appropriate.
If the individual is not satisfied with the results of the request, the Company shall internally document the issue,
and provide a response. The existence of the unresolved challenge will be transmitted to third parties, as
appropriate.
SECURITY OF PERSONAL INFORMATION
Personal information will be retained only as long as necessary and as required by applicable legislation and
securities regulations and will be disposed of in a manner that is appropriate to the sensitivity of the information.
We render client personal information non-identifying, or destroy records containing personal information once
the information is no longer needed. We use appropriate security measures when destroying client personal
information, including shredding paper records and permanently deleting electronic records.
Personal information will be protected by security safeguards, appropriate to the sensitivity of the personal
information. However, no system is completely secure therefore you are advised to take steps to protect your
information such as making strong passwords and using up-to-date antivirus software.
We will notify the Office of the Information and Privacy Commissioner of Alberta, and any other Privacy
Commissioners as required, without delay, of a security breach affecting personal information if it creates a real
risk of significant harm to individuals or as required under applicable laws.
DELETION OF YOUR ACCOUNT or DATA
Users can delete their account or data by tapping on 'Delete Account' under the Settings page of our application.
Or you may send an email to our privacy officer requesting deletion of your data.
CHALLENGING COMPLIANCE
Inquiries or complaints concerning compliance with this Privacy Policy should be addressed, in writing, to the
Company's Privacy Officer.
CHANGES TO THIS PRIVACY POLICY
We will occasionally update this Privacy Policy, and post 'Last Revised Date' at the top of this Privacy Policy.
We recommend that you review our Privacy Policy from time to time to inform yourself of any changes to this
Privacy Policy or any of our other policies or agreements. By continuing to use our Services, you will be deemd
to have agreed to any such modification or amendment.
QUESTIONS AND COMPLAINTS
If you have a question or concern about any collection, use or disclosure of personal information by the
Company, or would like to request access to your own personal information or deletion of your data, please
contact our Privacy Officer at our company email.