INTRODUCTION & SCOPE
SkiKrumb Trackers Inc. (“SkiKrumb” “we“, “us“, “our“) is a location tracking services provider. We provide technology that enables individuals to use our mobile application (the “App”) and website to view the location of tracked users within designated ski resorts in British Columbia (the “Resort” or “Resorts”).
By installing the App, creating a SkiKrumb account, or otherwise using the SkiKrumb Products and Services, you acknowledge the notices in this Policy and you consent to our collection, use, disclosure, and retention of your personal information in accordance with this Policy and as otherwise permitted by law. You may withdraw your consent at any time by giving SkiKrumb reasonable notice, but doing so may impact your ability to use the SkiKrumb Products and Services.
COLLECTION OF PERSONAL INFORMATION
SkiKrumb collects personal information from Users when they interact with us or use the SkiKrumb Products and Services. SkiKrumb also collects some personal information from Users automatically, which is addressed in more detail below.
In some cases, SkiKrumb may seek your consent for the use and disclosure of your personal information after it has been collected, but before it has been used or disclosed (e.g. where we want to use your personal information for a purpose not previously identified to you). We will not use or disclose your personal information for any new purpose without first identifying the new purpose and providing notice to you or obtaining your consent (as applicable), unless otherwise permitted by law.
You can always choose not to provide SkiKrumb with certain requested personal information, but then you may not be able to access or utilize all or part of the SkiKrumb Products and Services.
Personal Information Collected from Users
We collect the following types of personal information from Users:
- Contact information: We collect your personal information when you contact SkiKrumb directly to inquire about the SkiKrumb Products and Services. This may include your name, e-mail address, phone number, and other information that you choose to provide to us.
- Account, profile, and User information: We collect your personal information when you register for or modify the information associated with your account with SkiKrumb (“Account”) either through the App or on the Site. This includes information such as your first and last name, your e-mail address, phone number, username and password. If you are provided a Device for tracking by another User, that User may also add your first and last name to their Account.
- User Payment information: We do not collect credit card information directly from Users. We use a third party payment processor, presently Stripe, Inc., to handle payments for us. The third party service provider will receive your credit card information when you add it to your Account.
- Ratings and reviews: We collect the information you include in any feedback you provide to SkiKrumb through the Online Services or otherwise.
- Other information: We collect any other personal information that Users submit directly to SkiKrumb on a voluntary basis. For example, you may provide information to SkiKrumb in respect of a claim or dispute.
Personal Information Automatically Collected When Using the Online Services
- Device information: We collect your IP address, web browser type, mobile operating system, push notification tokens, application installations, mobile device carrier and manufacturer, and your mobile device identifier (e.g. IMEI numbers).
- Facebook, Apple, and Google information: If you register for an Account or login to your Account via your existing Facebook, Apple, or Google profile, SkiKrumb will receive basic information from such profile, which includes your name, email, and profile picture.
- Technical and usage information: We collect information about the sections of the Site and App that you visit, the date and time of your use of the Site and App and your in-media time, your actions within the Site and App, Site and App crashes and other system activity.
- Geolocation information: We collect the location of each Device. Due to the tracking nature of the Devices, Users will not have the option of disabling this feature.
- Cookies and tracking technology: SkiKrumb collects personal information when you access the Site and/or App via “cookies” and other similar tracking technologies such as Google Analytics and Google Tag Manager.
USE OF YOUR PERSONAL INFORMATION
SkiKrumb may use the personal information that it collects for the following purposes:
- Contact information: We use your contact information to contact and correspond with you directly about our relationship and your use of the SkiKrumb Products and Services. SkiKrumb may contact you to inform you about its services in different ways including by email, telephone, or other means to which you have agreed.
Where we have your consent to do so, we may send you information about SkiKrumb’s services, including general updates and announcements (see below for information on how to “opt-out” of receiving certain communications from us).
- Account and profile information: We use your Account and profile information to set up and provide you with access to the SkiKrumb Products and Services, to create and set up your Account and user profile, and to administer your use of the SkiKrumb Products and Services.
- Ratings and reviews: We use rating and review information to improve the SkiKrumb Products and Services, including to administer and resolve technical issues on the Site or App.
- Payment information: As explained above, we use a third party payment processor to handle payments.
- Device, technical and usage information: We use device information to understand traffic and activity on the Site and the App, and to enable us to improve the SkiKrumb Products and Services.
- Facebook, Apple, and Google information: If you register for an Account or login to your Account using an existing Facebook, Apple, or Google profile, we use the basic profile information in order to set up your Account, and to facilitate your login to your Account.
- Geolocation information: We collect Users’ geolocation to provide the Online Services and to enable Users to view the location of tracked users via the location of each Device, and to create daily replays of tracked Users’ movement. Such information may also be used to improve the Online Services. Users’ geolocation information may be shared with the Resort or other third parties that provide safety and rescue services solely for use in emergencies.
- Cookies and tracking technology: We use this information to track the activity of Users on the Site and the App, and to modify the Site and the App to reflect User preferences. Cookies enable our Site to save and retrieve information that you enter (for example, user preferences and settings). Cookies may remain on your device after you leave the Site (until the cookie expires or is deleted by you). You can disable cookies by adjusting the settings on your internet browser, however, disabling cookies may affect your ability to access some pages on the Site. We use other tracking technologies to understand how Users use the App.
- In general, SkiKrumb may also use the personal information we collect:
- To conduct data analysis, testing, research, and monitor and analyze usage and activity trends;
- To identify and prevent fraudulent activity and to protect security of the Site and App;
- To meet legal and regulatory requirements; and
- To facilitate such other services and activities, as we may identify to you at the time.
If you provide us with your e-mail address and “opt-in” to receiving messages from us via the e-mail address provided, you may receive electronic communications from us from time to time. These electronic communications will provide you with our contact information and a method to opt-out and unsubscribe from receiving marketing information and/or any further communications from us. SkiKrumb may use your e-mail address to communicate with you regarding important matters, such as information about your Account. You may not opt-out of receiving communications required by law, or communications that are necessary to provide you with the Skikrumb Products and Services.
SkiKrumb will only use your personal information for the purpose for which it was originally collected, or for a use consistent with that purpose, unless you expressly consent otherwise or it is permitted or required by law.
DISCLOSURE OF YOUR PERSONAL INFORMATION
Except as described in this Policy or in other situations where we have provided you with prior notice, have obtained your consent, or are obligated or permitted by law, SkiKrumb will not share your personal information with third parties.
In the Event of an Emergency
SkiKrumb may share a User’s name and location information with the Resort in the case of an emergency or other situation when it appears to be in the best interests of the individual.
Third Party Service Providers
SkiKrumb may disclose certain personal information to third party service providers with whom it has contracted to provide certain services on behalf of SkiKrumb.
The third party service providers will have access to personal information needed to perform their functions, but are only provided the limited amount of information required to perform their services. When SkiKrumb uses third party service providers, it requires the providers to protect your personal information in accordance with the law and with the same or more stringent security and privacy standards than SkiKrumb. Any such disclosure of your personal information by SkiKrumb to a third party service provider will be conditional upon the information being used solely for the purpose for which it has been disclosed.
Some of SkiKrumb’s third party service providers are located in the United States, so your personal information may be stored, accessed or used there, and may be subject to the laws and access by government or regulatory organizations in the United States. If you have any questions about SkiKrumb’s policies and practices with respect to service providers outside of Canada, including its collection, use, disclosure, and storage of personal information, you can contact the SkiKrumb Privacy Officer at the contact information listed in this Policy.
Where Required or Authorized by Law
SkiKrumb may also disclose your personal information where authorized or required by law. For example, we may disclose your personal information to comply with a subpoena, in response to a law enforcement body with the lawful authority to obtain the information, pursuant to an investigation into the breach of a law, or to our legal counsel.
SECURITY & PROTECTION OF YOUR PERSONAL INFORMATION
SkiKrumb takes reasonable steps to protect your personal information. We use administrative, technical, and physical safeguards to protect against unauthorized access, collection, use, disclosure, and disposal, in a manner appropriate to the sensitivity of the information.
RETENTION OF YOUR PERSONAL INFORMATION
Information collected by SkiKrumb is maintained in accordance with applicable privacy legislation and SkiKrumb’s retention policies and practices. When a User closes their Account, any personal information is deleted within 90 days.
CORRECTION AND ACCESS TO YOUR PERSONAL INFORMATION
All personal information in your Account and user profile is accessible by you. You can make changes to certain personal information that SkiKrumb holds about you by editing the information in your Account. You are responsible for keeping the personal information in your Account up to date and accurate.
You may request access to your personal information and/or correction of that information by contacting SkiKrumb in writing at the contact information noted below, with sufficient detail to enable SkiKrumb to identify the personal information being sought. When you contact SkiKrumb, we may ask for further information to confirm your identity and the nature of the information being sought. We will respond to your request in accordance with the law.
SkiKrumb may charge a reasonable fee according to the cost required to retrieve and provide access to the requested information. We may provide an estimate of the fee in advance and, in some cases, will require a deposit for all or part of the fee.
QUESTIONS AND CONCERNS
Questions or concerns regarding this Policy and how we handle your personal information can be directed to the SkiKrumb Privacy Officer.
Email: [email protected]
CHANGES TO THE POLICY
SkiKrumb may update this Policy from time to time by posting a new version of the Policy on the Online Services. If there are significant changes made to the Policy, we may notify Users in advance through the Online Services or by e-mail. SkiKrumb’s collection, use, disclosure, and retention of your personal information will be governed by the version of the Policy in effect at that time. We suggest that you review this Policy periodically.
Last updated: December 6, 2023