Moby Privacy Policy – Western Fibre Communications Corp.  

 Scope 

This Moby Privacy Policy applies to all residential, commercial, and business relationships in which WESTERN FIBRE COMMUNICATIONS CORP. is engaged. The Policy is intended to comply with privacy legislation relating to activity in all jurisdictions in which WESTERN FIBRE COMMUNICATIONS CORP. operates. 

Privacy Policy Officer 

In order to ensure compliance with our Moby Privacy Policy and applicable privacy legislation, WESTERN FIBRE COMMUNICATIONS CORP. has appointed a Privacy Officer.  If there are any questions about the application of this policy, please contact WESTERN FIBRE COMMUNICATIONS CORP.’s Privacy Officer: 

Privacy Officer, Western Fibre Communications Corp., 650-840 7 Avenue SW, Calgary, Alberta, T2P 3G2, 403-986-6629, E-mail: privacy.officer@getmoby.com 

Collection, Use and Disclosure of Personal Information 

For purposes of this Customer Privacy Policy, personal information means any information about an identifiable individual, other than the person’s business title or business contact information when collected, used or disclosed in the course of commercial activity, to conduct business and to provide services and products. 

Type of Information 

The type of information WESTERN FIBRE COMMUNICATIONS CORP. collects includes the following: 

• Information such as name, home address, telephone number and e-mail address 
• Copies of any agreements with WESTERN FIBRE COMMUNICATIONS CORP. 
• Information provided to WESTERN FIBRE COMMUNICATIONS CORP. such as preferences, feedback and comments 

• Credit and financial information 

Moby Use of Information 

WESTERN FIBRE COMMUNICATIONS CORP. uses the personal Moby information above for different purposes relating to the management of our business and our business relationships. These purposes include, but are not limited to the following situations. 

• Establishing, maintaining and managing a business relationship so that WESTERN FIBRE COMMUNICATIONS CORP. may provide the services or products requested 
• Enabling WESTERN FIBRE COMMUNICATIONS CORP. to comply with requests such as preferred method of communication 

• Sharing personal information with any third parties under direction or consent 
• Enabling WESTERN FIBRE COMMUNICATIONS CORP. to review the products and services that WESTERN FIBRE COMMUNICATIONS CORP. provides so that WESTERN FIBRE COMMUNICATIONS CORP. may understand the requirements for WESTERN FIBRE COMMUNICATIONS CORP. products and services and improve WESTERN FIBRE COMMUNICATIONS CORP. products and services 
• Protecting WESTERN FIBRE COMMUNICATIONS CORP. business from error, fraud, theft and damage to WESTERN FIBRE COMMUNICATIONS CORP. goods and property 
• Enabling WESTERN FIBRE COMMUNICATIONS CORP. to comply with applicable law or regulatory requirements 
• Safeguarding and protecting WESTERN FIBRE COMMUNICATIONS CORP. ’s confidential information 

• Other purposes reasonably required for the management of WESTERN FIBRE COMMUNICATIONS CORP. business relationships and the management of WESTERN FIBRE COMMUNICATIONS CORP. ’s business 

Sharing Information 

WESTERN FIBRE COMMUNICATIONS CORP. may share personal Moby information with its board members, employees, auditors, contractors and consultants and other parties who require such information to assist WESTERN FIBRE COMMUNICATIONS CORP. with administering WESTERN FIBRE COMMUNICATIONS CORP. business relationship with you. These include third parties that provide services to WESTERN FIBRE COMMUNICATIONS CORP. or on our behalf, third parties that collaborate with WESTERN FIBRE COMMUNICATIONS CORP. in the provision of services to parties with whom WESTERN FIBRE COMMUNICATIONS CORP. contracts to perform our services. The amount of Moby information disclosed will be the minimum required for the 3rd party to perform its duties or to fulfill their contract with WESTERN FIBRE COMMUNICATIONS CORP. 

Cookies 

WESTERN FIBRE COMMUNICATIONS CORP. uses cookies on our website to improve your experience and to help us understand how our website is being used. Cookies are small files that are stored on your device when you visit our website. We use both session cookies and persistent cookies. Session cookies are deleted when you close your browser, while persistent cookies remain on your device until they expire or you delete them. You can choose to disable cookies in your browser settings, but this may impact your ability to use our website. 

Privacy Policy Disclosure Conditions 

However, WESTERN FIBRE COMMUNICATIONS CORP. will only disclose information to other parties if: 

• They have a privacy policy of their own 
• Their privacy policy is equal to or better than the restrictions in this policy 
• In the absence of the 3rd party having their own privacy policy, they sign a Non-Disclosure Agreement with WESTERN FIBRE COMMUNICATIONS CORP. 

• They agree not sell your private information to other parties 

In addition, personal information may be disclosed or transferred to another party in the event of a change in ownership of, or a grant of a security interest in, all or part of WESTERN FIBRE COMMUNICATIONS CORP. through a sale transaction or some other form of business combination, merger or joint venture. WESTERN FIBRE COMMUNICATIONS CORP. will disclose personal information in these circumstances only when the third parties agree to use such Moby personal information solely for the purposes evaluating and carrying out the transaction and, with respect to that information, to act in manner consistent with the principles articulated in this Privacy Policy. 

Moby Privacy Policy Consent 

WESTERN FIBRE COMMUNICATIONS CORP. requires consent to collect, use and disclose your personal information in accordance with this Policy. Consent may be expressed or implied. Express consent may be given orally or in writing, including electronic transmission. Implied consent is consent that can be reasonably inferred by your action or inaction and by signing a contract with WESTERN FIBRE COMMUNICATIONS CORP. or completing and online signup form for services. By providing WESTERN FIBRE COMMUNICATIONS CORP. with the personal information described in this Policy, WESTERN FIBRE COMMUNICATIONS CORP. assumes implied consent for WESTERN FIBRE COMMUNICATIONS CORP. to use and disclose your personal information in accordance with this Policy. 

Consent may be withdrawn for WESTERN FIBRE COMMUNICATIONS CORP. to collect, use and disclose Moby personal information at any time, subject to legal and contractual obligations in our business relationship. There must be reasonable notice of the withdrawal of consent. All communications with respect to the withdrawal or limitation of consent should be directed to the WESTERN FIBRE COMMUNICATIONS CORP. Privacy Officer in writing. 

In some circumstances, WESTERN FIBRE COMMUNICATIONS CORP. is entitled, or required, to disclose personal information without consent. These circumstances include, but are not limited to: 

• Protection of health or safety 
• Necessary disclosure for an investigation or proceeding 
• Required or authorized disclosure for by law 
• Required to comply with a subpoena, warrant or order of a court or other body authorized to compel production of the information 

• A public body requires it and relates to an investigation of an offence 
• The disclosure is to a lawyer who is representing WESTERN FIBRE COMMUNICATIONS CORP. 
• The disclosure is required to respond to an emergency 
• Where the personal information is publicly available 

Accuracy of Personal Moby Privacy Information 

WESTERN FIBRE COMMUNICATIONS CORP. endeavors to ensure that any personal information in its possession is as accurate, current and complete as necessary for the purposes for which WESTERN FIBRE COMMUNICATIONS CORP. uses that information. If personal information changes or is deemed to be not accurate, please notify WESTERN FIBRE COMMUNICATIONS CORP. as soon as reasonably possible. Any request to verify or correct personal information must be made in writing to WESTERN FIBRE COMMUNICATIONS CORP.’s Privacy Officer. In some circumstances, WESTERN FIBRE COMMUNICATIONS CORP. may not agree to the request to change personal information, but will instead append an alternative text to the record in question. 

Retention of Personal Moby Information 

WESTERN FIBRE COMMUNICATIONS CORP. keeps personal Moby information only as long as it is required for the reasons it was collected. The length of time WESTERN FIBRE COMMUNICATIONS CORP. retain information varies, depending on the product or service and the nature of the information. This period may extend beyond the end of a business relationship with WESTERN FIBRE COMMUNICATIONS CORP. but it will only be for as long as it is necessary for WESTERN FIBRE COMMUNICATIONS CORP. to have sufficient information to respond to any issues that may arise at a later date and to comply with applicable law and regulatory requirements. When WESTERN FIBRE COMMUNICATIONS CORP. no longer requires personal information, WESTERN FIBRE COMMUNICATIONS CORP. will either destroy or erase it, or WESTERN FIBRE COMMUNICATIONS CORP. will make it anonymous such that it cannot be associated with or tracked. 

Safeguarding Personal Moby Information 

WESTERN FIBRE COMMUNICATIONS CORP. is committed to protecting the security of personal information. WESTERN FIBRE COMMUNICATIONS CORP. endeavors to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to prevent personal information from loss and unauthorized access, copying, use, modification or disclosure. 

Access to Your Personal Moby Information 

An individual or corporation may ask to see the personal information collected by WESTERN FIBRE COMMUNICATIONS CORP. A request to review personal information must be made in writing to WESTERN FIBRE COMMUNICATIONS CORP. Privacy Officer. WESTERN FIBRE COMMUNICATIONS CORP. will endeavor to provide the information requested within a reasonable time from the date of the written request, or within the time otherwise required by law. 

Upon receipt of a request to review personal information, WESTERN FIBRE COMMUNICATIONS CORP. may request specific information to enable WESTERN FIBRE COMMUNICATIONS CORP. to confirm identity and right to access such information. WESTERN FIBRE COMMUNICATIONS CORP. may also require information that would assist WESTERN FIBRE COMMUNICATIONS CORP. in locating any personal information. WESTERN FIBRE COMMUNICATIONS CORP. may charge a fee to access personal information; if so, WESTERN FIBRE COMMUNICATIONS CORP. will notify the applicant of that fee at the time of the request or within a short time thereafter. 

Rights Reserved 

WESTERN FIBRE COMMUNICATIONS CORP. reserves the right to decline to provide access to personal information in certain circumstances. These include, but are not limited to, circumstances where the information requested: 

• Would disclose personal information, including opinions, about another individual 
• Would disclose WESTERN FIBRE COMMUNICATIONS CORP. ’s trade secrets or other confidential business information 
• Is subject to lawyer-client privilege 
• Is not readily retrievable and the burden or cost of providing it would be disproportionate to the value of the information 
• Does not exist or cannot be found 

• Could result in serious harm to the individual requesting it, serious harm to the life, safety or health of another person, or serious emotional harm or embarrassment to another individual 
• May harm or interfere with law enforcement activities and other investigative or regulatory functions of a body authorized by statute to perform such functions 
• May be or is required to be withheld by other legislation 

Where information requested will not or cannot be disclosed, WESTERN FIBRE COMMUNICATIONS CORP. will provide the reasons for non-disclosure. 

Revisions to this Moby Privacy Policy 

WESTERN FIBRE COMMUNICATIONS CORP. may amend this Customer Privacy Policy from time to time to reflect changes in its legal or regulatory obligations or in the manner in which we deal with your personal information. We will post any revised version of this Policy on our website at www.getmoby.com 

Interpretation of this Policy 

The Privacy Officer has the responsibility and authority to interpret and administer this Policy. This Policy does not create or confer any additional rights or obligations to those imposed under provincial or federal privacy legislation. Should there be, in a specific case, any inconsistency between this Policy and applicable provincial or federal privacy legislation, and then this Policy will be interpreted to give effect to and comply with such privacy laws. 

MOBY WIFI APP 

How WESTERN FIBRE COMMUNICATIONS CORP. collects your Information 

WESTERN FIBRE COMMUNICATIONS CORP. collects, and processes information provided directly by you when you install the Moby WIFI App and register for an account to use the Moby WIFI App. Specifically, this information includes: 

• Your name, email address, location, phone number. 
• Browser information and session cookies related to your access and use of the Moby WIFI App. 
• Data insights WESTERN FIBRE COMMUNICATIONS CORP. attains based on correlation and analytics of your information collected in providing the Moby WIFI App, which may be used in aggregated and dis-aggregated formats or to obtain trend analytics, to provide the Moby WIFI App; and 

• Use of the above-described collected information in aggregated and dis-aggregated formats to enhance our current App or to provide App features.  

How WESTERN FIBRE COMMUNICATIONS CORP. uses the Information 

WESTERN FIBRE COMMUNICATIONS CORP. uses the information collected as described in this Privacy Policy, including personal information, to: 

• Provide you with the Moby WIFI App as described in the Agreement. 
• Implement, improve and/or enhance the Moby WIFI App, including making future releases available to you. 

• Carry out WESTERN FIBRE COMMUNICATIONS CORP. obligations as described or authorized in the Agreement and this Privacy Policy. 
• Enforce WESTERN FIBRE COMMUNICATIONS CORP. rights arising from the Agreement between you and WESTERN FIBRE COMMUNICATIONS CORP.; and 
• Fulfill any other purpose authorized by you and reasonably required for the Moby WIFI App.