Privacy Policy

Privacy Policy

cirkuit Inc. (“cirkuit“, “we” or “us“) is committed to respecting and protecting the personal information we collect.  This privacy policy, as amended from time to time (this “Privacy Policy”) describes the personal information that we collect and explains how we use, store, process, disclose and safeguard that information.  Please review this entire document carefully.

Privacy Policy for Canada

It is our policy to comply with the privacy legislation within each jurisdiction in which we operate.  Sometimes privacy legislation and/or an individual’s right to privacy are different from one jurisdiction to another.  This Privacy Policy covers only those activities that are subject to the provisions of Canada’s federal and provincial laws, as applicable.  

What is Personal Information?

For the purposes of this Privacy Policy, “personal information” refers to any information relating to an identified or identifiable natural person, such as an identification number, physical, physiological, mental, economic, cultural, or social identifiers.  

What Does cirkuit Do?

cirkuit owns and operates a technology system designed to, inter alia, detect and alert on various incidents, which currently includes water leaks and may expand to include other incidents such as gas leaks, humidity, smoke, heat, etc. (the “cirkuit System“).  The cirkuit System is designed for cirkuit to provide condominiums and other multi-unit buildings (the “Host”) with certain services including:

  • alerting the Host, owners and, where applicable, tenants and occupants of detected incidents in their units;
  • alerting the Host, building managers and other service providers of detected incidents in the buildings; and
  • generating various reports relating to incidents and related matters

(collectively, the “Services”).  Upon engaging cirkuit to provide the Services, the Host will have the ability to grant different levels of access and use of the Services to various individuals including, without limitation, the owners, tenants and occupants of units in the building as well as the building managers and other services providers (collectively, the “Authorized Users”). 

What Personal Information Do We Collect?

In connection with providing the Services, cirkuit collects a variety of personal information, including:

  • contact information including the full name, address, email and telephone number of each Authorized User;
  • account information including the username and password of each Authorized User;
  • certain demographic information about the Authorized Users;
  • certain information and data from the devices on which the cirkuit System is accessed and used by Authorized Users including the device type, device identifier, IP address, browser type and version, operating system, geographic location data, access information and duration of use;
  • data and information about each building and the units therein including information about the design, structure, floor plans, utility infrastructure and layout;
  • data and information about any incidents that occur anywhere in the building including any of the units therein;
  • any information required to provide technical support; and
  • comments, questions, feedback and other information from the Host and Authorized Users via surveys, questionnaires, polls and testimonials about the cirkuit System.

Website.  We collect usage information from visitors to our public website located at https://cirkuit.io (the “Public Website”).  This information includes IP address and domain used to access the Public Website, the type and version of the visitor’s browser, the website the visitor came from to access the Public Website, the page the visitor entered and exited at, any website page within the Public Website that is viewed by that IP address and what country the visitor is from.  We use this information to monitor the Public Website’s performance (such as number of visits, average time spent, page views) and to maintain, manage and improve our operations, and as otherwise described in this Privacy Policy.  We may engage third-party service providers to assist us in gathering and analyzing this information.

Cookies.  We may use a technology called “cookies”. A cookie is a tiny data file that both our web-based application through which the cirkuit System is accessed and used by Authorized Users as well as the Public Website (collectively, the “cirkuit websites”) send to a visitor’s browser, which may then be stored on the visitor’s hard drive.  The cookie acts as an identification card and allows the cirkuit websites to recognize the visitor’s computer or device and records the date and time that the visitor interacts with the cirkuit websites.  Cookies may provide us and our third-party service providers with information that we will use to personalize the cirkuit websites in accordance with a visitor’s preferences and for marketing purposes.  Most web browsers are set to accept cookies; however, a person may change this setting to have the web browser either: (i) notify them prior to a website placing a cookie on their hard drive so that they can decide whether or not to accept the cookie; or (ii) automatically prevent the placing of a cookie on their hard drive. If a person decides not to accept cookies from the cirkuit websites, they may not be able to take advantage of all of the features of the cirkuit websites.

Why Do We Collect Personal Information?

We collect the personal information identified above for the purpose of operating, managing, maintaining and improving our operations relating to the cirkuit System and the services associated therewith, which includes:

  • providing the Host and Authorized Users with access to and use of the cirkuit System;
  • conducting analyses of the data and information collected by the cirkuit System to generate various reports and information relating to incidents and related matters;
  • analyzing and using data and information collected by cirkuit to create and commercialize new products and services that strive to assist multi-unit buildings with (i) detecting, remedying and reducing incidents and (ii) assessing and improving their risk profiles;
  • analyzing and using data and information collected by cirkuit to (i) create and commercialize  new products and services that provide insurance providers with the information required to more accurately assess the risks profiles for multi-unit buildings and thereby strive to reduce the costs of insurance for multi-unit buildings overall or (ii) establish new insurance products that strive to reduce the costs of insurance for multi-unit buildings overall;
  • conducting research and development activities into new or existing products or services;
  • monitoring the performance of, and performing quality control activities with respect to, the cirkuit System;
  • helping us operate, manage, maintain, market and improve our operations relating to cirkuit System by:
  • obtaining comments, suggestions and feedback;
  • conducting surveys or polls; and
  • obtaining testimonials;
  • protecting the data collected, stored or otherwise processed by cirkuit System by, among other things, monitoring, detecting, investigating and remedying any suspected or actual breaches of any Host Agreement, the Authorized User Terms and Conditions, this Privacy Policy or any of our policies and procedures relating thereto;
  • giving notice of any data security breaches or legal proceedings;
  • giving notice of any changes to this Privacy Policy; and
  • any other reasonable purpose for which consent is obtained.

How Do We Use and/or Disclose the Personal Information We Collect?

We only use and/or disclose personal information we collect:

  • for the purposes described in this Privacy Policy;
  • to:
  • our directors, officers, employees, contractors, consultants, affiliates and other parties who require such information to assist us with fulfilling the purposes described in this Privacy Policy;
  • third-party service providers (including cloud-based service providers), agents or independent contractors in accordance with the provisions below;
  • as permitted or required by applicable law or regulatory requirements;
  • when required to comply with valid legal processes such as search warrants, subpoenas, court orders or other legally valid inquiries or orders;
  • during emergency situations or where necessary to protect the safety of a person or group of persons; and
  • for any additional purposes for which we have obtained your consent to the use or disclosure of your personal information. 

In addition, from time to time, we process personal information that you submit to cirkuit to create derivative data that is aggregated with other data and de-identified (i.e., the personal information is processed so that it cannot be linked back to you as an identifiable individual) (“Anonymized Content”).  We use, process, compile, save, store, copy, disclose, distribute, sell, assign, transfer, convey and sublicense any Anonymized Content for cirkuit’s other internal or commercial business purposes. 

We may use third-party service providers to assist us with operating, managing, maintaining and improving our operations relating to the cirkuit System and the services associated therewith.  In particular, we may engage third-party service providers to host the components of cirkuit System, store data, provide back-up services, conduct data analytics and/or obtain customer feedback.  Personal Information may be processed and stored by cirkuit or its third-party service providers, as permitted by applicable law. Third-party service providers may only use and/or disclose personal information to the extent required to perform their designated functions.  In addition, we will ensure that they provide privacy and security protections which are comparable to those provided by cirkuit.  For more information about the way in which our third-party service providers treat personal information, please contact our Privacy Officer.

We and/or our third-party service providers may use and/or disclose your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.  In particular, we and our third-party service providers may disclose personal information referred to herein in response to a search warrant, subpoenas, court orders or other legally valid inquiry or order (which may include lawful access by Canadian or other foreign governmental authorities, courts or law enforcement agencies), to other organizations in the case of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise required or permitted by applicable Canadian or other foreign laws.

In addition, we may disclose or otherwise transfer personal information to another party in connection with a prospective or completed business transaction including an asset or share sale, merger, amalgamation, plan of arrangement or some other form of business combination (including transfers made as part of insolvency or bankruptcy proceeding) involving any of cirkuit’s assets or shares or as part of a corporate reorganization or other change in corporate control; provided, however, that such party is bound by appropriate agreements or obligations and required to use or disclose the personal information in a manner consistent with the use and disclosure provisions of this Privacy Policy.

Consent is Important to Us

It is important to us that we collect, use or disclose personal information where we have consent to do so.  Depending on the sensitivity of the personal information, consent may be implied, deemed (using an opt-out mechanism) or express.  Express consent can be given orally, electronically or in writing.  Implied consent is consent that can reasonably be inferred from an action or inaction.

You may change or withdraw your consent at any time, subject to legal or contractual obligations.  However, it is important to note that we may not be able to destroy or alter our archival/backup data, or secure the removal of personal information where it has been disseminated or used by third-parties. 

We may collect, use or disclose personal information without your knowledge or consent where we are permitted or required to do so by applicable law or regulatory requirements. 

All communications with respect to such withdrawal or variation of consent should be in writing and addressed to our Privacy Officer. 

How is Personal Information Protected?

We are committed to protecting personal information that we collect, store or otherwise process from improper or unauthorized access, collection, use, disclosure, copying, modification, disposal or destruction.

We have implemented administrative, technical, physical and procedural safeguards in order to protect against such unauthorized behavior, taking into account the sensitivity of the information in question.  These safeguards include passwords, encryption, firewalls and other technologies and practices.  However, cirkuit cannot prevent all possible improper or unauthorized access, collection, use, disclosure, copying, modification, disposal or destruction of personal information and, subject to applicable laws, will not be responsible for any damages or liabilities relating thereto.

We will make commercially reasonable efforts, where required by law, to notify all of the applicable parties in the event of any improper or unauthorized access, collection, use, disclosure, copying, modification, disposal or destruction, without delay.

The security of personal information is important to us.  Please advise our Privacy Officer immediately if you become aware of any incident involving the loss of or unauthorized access to or disclosure of personal information that we collect, store or otherwise process.

How is Personal Information Retained?

In general, cirkuit retains personal information in accordance with applicable laws.  

How can Personal Information be Accessed, Updated or Corrected?

Subject to certain limited exceptions prescribed by law, you may submit a request to access, update or correct your personal information.  To review, verify or correct your personal information, please submit a written request to our Privacy Officer. 

When making any such request, please note that we may request specific information to enable us to confirm your identity and determine whether you have the right to access, update or correct the personal information relating to such request. 

The right to access the personal information that we hold about you is not absolute.  There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you.  In addition, your personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices.  In the event that we cannot provide you with access to your personal information, we will endeavor to inform you of the reasons why, subject to any legal or regulatory restrictions. 

We may charge a fee to access personal information; however, we will advise you of any fee in advance.  If you require assistance in preparing your request, please contact our Privacy Officer.

Inquiries or Concerns? 

If you have any questions about this Privacy Policy or concerns about how we manage personal information, please contact our Privacy Officer by telephone, in writing or by e-mail.  We will endeavor to answer your questions and advise you of any steps taken to address the issues raised by you.  If you are dissatisfied with our response, you may be entitled to make a written submission to the Privacy Commissioner responsible for your jurisdiction.

Privacy Officer

We have appointed a Privacy Officer to oversee compliance with this Privacy Policy.  The contact information for our Privacy Officer is as follows:  

Kaila Hoar
kaila@cirkuit.io

Revisions to this Privacy Policy

We may amend this Privacy Policy from time to time in order to reflect changes in our legal or regulatory obligations or in the manner in which we deal with personal information.  We will post any amended version of this Privacy Policy on the Website.

This Privacy Policy was last updated on January 1, 2021.

Interpretation of this Privacy Policy

Any interpretation associated with this Privacy Policy will be made by our Privacy Officer.  This Privacy Policy includes examples but is not intended to be restricted in its application to such examples; therefore, where the word “including” is used, it shall mean “including without limitation”.

This Privacy Policy does not create or confer upon any individual any rights or impose upon cirkuit any rights or obligations outside of, or in addition to, any rights or obligations imposed by Canada’s federal and provincial privacy laws, as applicable. Should there be, in a specific case, any inconsistency between this Privacy Policy and Canada’s federal and provincial privacy laws, as applicable, this Privacy Policy shall be interpreted, in respect of that case, to give effect to, and comply with, such privacy laws.