Introduction


Just Buro Inc. (“Buro”) respects your (“Your”) privacy and is committed to protecting it through Buro’s compliance with this privacy policy (the “Privacy Policy”). This means Buro does not transfer, distribute, disclose, rent or sell any of Your personal information to third parties except as provided for in this Privacy Policy or as specifically consented by You.

Buro has developed policies and procedures consistent with the Personal Information Protection and Electronic Documents Act (“PIPEDA”), and other relevant privacy laws

By using (the word “use” in this Privacy Policy will mean “access or use”) Buro’s Services, including Buro’s Services (currently located at justburo.com) and App, You expressly consent to Buro’s collection, use and disclosure of Your personal information in accordance with this Privacy Policy.

This Privacy Policy is incorporated into and subject to Buro’s Terms of Service. Undefined capitalized terms used in this Privacy Policy have the meanings given to them in Buro’s Terms of Service.

Scope


This Privacy Policy applies to all Personal Information collected, used or disclosed by Buro from users of Buro’s Services (“Users”) , including You. “Personal Information” is any information in any form that identifies or can identify an individual and includes any information provided to Buro.

This Privacy Policy also applies to information that is about You, but individually does not identify You, as described below.

Accountability


Buro is responsible for the Personal Information under its possession and control. Buro has designated a Privacy Officer to be responsible for its compliance with this Privacy Policy and privacy legislation.

Information Buro Collects


Personal Information

  1. Personal Information that Buro collects includes, but is not limited to:
    • Registered User Account profile information, including name, e-mail address, address, date of birth, usernames, passwords, phone numbers, and mailing address;
    • Billing and payment information, including credit card information and bank account details;
    • Shipping and return information, including mailing address;
    • Device information, including the type of mobile device to which You have downloaded Buro’s App;
    • Geo-location information;
    • Service requests and inquiries; and
    • Any other Personal Information that You may provide when You set-up a Registered User Account with Buro, use the Services, or when you contact Buro with questions and/or inquiries;
    • Technical support records;
    • Service requests and inquiries; and
    • Any information that Buro collects from You that is intended to improve and personalize Buro’s Services.

b. Non-Personal Information

Buro collects non-Personal Information (“NPI”) about Users when they interact with the Services. For instance, NPI may include, but is not limited to, browser name, type of computer or device, and technical information about a User’s means of connecting to the Services, such as operating system, Internet service provider utilized, and mobile network information. See the section below entitled “How does Buro collect, use and share NPI? How does Buro use cookies?” for more information.

Please note that Personal Information does not include information that is aggregated or anonymized in such a manner that it cannot be connected to You or any of other Users. Such information by itself or together cannot be tracked to a specific individual’s Personal Information.

  1. How does Buro use Personal Information?

    Buro collects Personal Information for the following purposes:

    • to provide Services to You and other Users;
    • to facilitate transactions between You and other Users via the Services;
    • to create and administer Your Registered User Account, including to authenticate You on log-in;
    • to establish and maintain responsible commercial relations and to communicate with You in order to provide the Services. This includes, but is not limited to, communications relating to advertising, promotion, billing and payment, and Registered User Account verification;
    • permit PayPal payment processor, to provide payment processing services;
    • to respond to any correspondence You may direct to Buro;
    • to understand Buro’s Users’ needs and preferences;
    • to enforce Buro’s Terms of Service;
    • to provide You with Service or administrative messages;
    • to meet legal and regulatory requirements;
    • to prevent, detect and mitigate illegal, fraudulent, or counterfeit activities;
    • to improve the Services; and
    • for any other reasonable purposes for which You may have provided Your express consent or in which Your consent can be reasonably implied.
  2. In addition, we may use Personal Information, on an aggregated de-identified basis, for research purposes to improve the Services. This aggregated de-identified information does not identify any individual and therefore is considered and treated as NPI under this Privacy Policy.


How does Buro collect, use and share NPI? How does Buro use cookies?
Buro uses NPI in an ongoing effort to better understand and serve the Users of Buro’s Services, to provide the Services and to improve the content and functionality of the Services.

For instance, Buro uses NPI to provide relevant, targeted advertising to Users of the Services, to monitor traffic, and to collect statistical data.

Buro uses NPI in an ongoing effort to better understand and serve the Users of Buro’s Services, to provide the Services and to improve the content and functionality of the Services.

For instance, Buro uses NPI to provide relevant, targeted advertising to Users of the Services, to monitor traffic, and to collect statistical data.

Buro also conducts research on Buro’s User demographics and behavior based on Personal Information the NPI that Buro has collected. This research will be compiled and analyzed on an aggregated basis and this aggregate does not identify any individual and therefore is considered and treated as NPI under this Privacy Policy.

No NPI by itself, or together with aggregated Personal Information (which, as explained below, is treated as NPI under this Privacy Policy), can be tracked to a specific individual's Personal Information.

The NPI collected is used to monitor traffic, provide the Services, and conduct internal research on Buro’s Users’ to better understand and serve them, including Users’ size, usage patterns, demographics, interests and behaviors.

The Services may automatically receive and store certain types of NPI about Users’ use of the Services and their devices, including IP address, browser type, web pages viewed, date and time, device unique identifier, mobile network information, mobile stored information and files, and device phone number, as well as how users interact with Buro. In addition, Buro uses different types of technology to collect this information, such as log files, embedded scripts, cookies, web beacons, and pixel tags.

The App also may access metadata and other information associated with other files stored on Your device. This may include, for example, photographs, audio and video clips ,personal contacts, and address book information.

The NPI collected by Buro will not be shared with third parties, except as expressly indicated in this Privacy Policy, or with Buro’s Affiliates (as defined below), business partners and other third parties to describe Buro’s Services and for other lawful purposes.

Cookies


Buro uses cookies to enhance Users’ experiences. Users’ web browsers place cookies on their computers for record-keeping purposes and sometimes to track information about them. Cookies help Buro accurately understand how many consumers are visiting Buro’s Website, how often Users visit the Website, what Content Users are most interested in, and how they prefer to interact with Content on the Website. For example, a cookie will allow Buro to remember certain things like Your Internet Protocol (IP) address (IP addresses are strings of numbers that identify senders and receivers of information sent across the Internet), Your login information, the time and duration of Your visits, how You navigated through Buro’s content and where You exited the Website. To save You the time of re-entering Your login information every time You come back to Buro’s Website, Buro may link information contained in a cookie to Your email address. Buro does not use cookies to retrieve information from Your computer that Buro did not originally send in a cookie.

Buro uses Google Analytics which uses cookies to track NPI about traffic and visitors to the Buro Services in the aggregate to compile statistical reports about the activity on the Services as well as to benchmark the Services to other third parties who also use Google Analytics. This information is used by Buro to improve the Services and their functionality. This data may be used to show You advertising on any Google or Google affiliated Services.

You may disable cookies using Your browser's settings. Please consult Your browser's help function for information on how to disable cookies. Note that if You disable cookies, certain features of Buro’s Services may not function to their fullest potential.

Consent


Buro respects Your privacy and, unless otherwise required by law, Buro will not collect, use or disclose Your Personal Information without Your prior consent. Your consent may be expressed or implied. You may expressly give Your consent in writing, verbally or through any electronic means. In certain circumstances, Your consent may be implied by Your actions. For example, providing Buro Personal Information to register for Buro’s Services is implied consent to use such information to provide You the associated Services.

Where appropriate, Buro will generally seek consent for the use or disclosure of the information at the time of collection. In certain circumstances, consent with respect to use or disclosure may be sought after the information has been collected but before use (for example, when Buro wants to use information for a purpose other than those identified above). In obtaining consent, Buro will use reasonable efforts to ensure that a customer is advised of the identified purposes for which Personal Information collected will be used or disclosed.

The form of consent sought by Buro may vary, depending upon the circumstances and type of information disclosed. In determining the appropriate form of consent, Buro shall take into account the sensitivity of the Personal Information and the reasonable expectations of Buro’s Users. Buro will seek express consent when the information is likely to be considered sensitive. Implied consent will generally be appropriate where the information is less sensitive.

You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. In order to withdraw consent, You must provide notice to Buro in writing.

Important Information About Platform Permissions


Most mobile platforms (iOS, Android, etc.) have defined certain types of device data that apps cannot access without Your consent. And these platforms have different permission systems for obtaining Your consent. The iOS platform will alert You the first time the App wants permission to access certain types of data and will let You consent (or not consent) to that request. Android devices will notify You of the permissions that the App seeks before you first use the App, and Your use of the App constitutes your consent.

Limiting Use, Disclosure and Retention


As noted above, Buro does not disclose Your Personal Information to third parties, except as provided for in this Privacy Policy.

When You Lend or Borrow an item via the Services, the Lender or Borrower (as applicable) may receive Your Personal Information for item delivery and return purposes. Lenders and Borrowers are strictly prohibited from using Your information for anything other than such purposes.

Your Personal Information may be transferred to third party suppliers, contractors and agents (“Affiliates”) who are contracted by Buro to assist it in providing and developing products, services and/or the Services. Such Affiliates will only use Your Personal Information for the purposes identified in this Privacy Policy.

We use PayPal for payment processing. PayPal’s privacy policy is available at https://paypal.com/ca/webapps/mpp/ua/privacy-full.

We also various third party providers for identification verification, such as:

Twilio, for phone number and e-mail verification. Twilio’s privacy policy is available at https://www.twilio.com/legal/privacy; and
Onfido, for driver’s license verification. Onfido’s privacy policy is available at https://onfido.com/privacy/.

In the event Your Personal Information is disclosed to a third party pursuant to a business transaction, Buro will ensure that it has entered into an agreement under which the collection, use and disclosure of the information is related to those purposes that relate to the transaction.

Subject to the foregoing, only Buro’s and Buro’s Affiliates’ employees with a business need to know, or whose duties reasonably so require, are granted access to Personal Information about Buro’s Users. All such employees will be required as a condition of employment to contractually respect the confidentiality of Buro’s Users’ Personal Information.

Buro will retain Personal Information for only as long as required to fulfill the identified purposes or as required by law. Personal Information that is no longer required to fulfill the identified purposes will be destroyed, erased or made anonymous according to the guidelines and procedures established by Buro.

Buro will disclose Personal Information without Your knowledge or consent if Buro receives an order, subpoena, warrant or other legal requirement issued by a court, tribunal, regulator or other person with jurisdiction to compel disclosure of Your Personal Information. If Buro receives a written request from a police officer or other law enforcement agency with authority to request access to Your Personal Information in the course of an actual or potential investigation into a breach of a law, Buro’s policy is to provide the requested information.

Buro will disclose Personal Information without Your knowledge or consent if Buro receives an order, subpoena, warrant or other legal requirement issued by a court, tribunal, regulator or other person with jurisdiction to compel disclosure of Your Personal Information. If Buro receives a written request from a police officer or other law enforcement agency with authority to request access to Your Personal Information in the course of an actual or potential investigation into a breach of a law, Buro’s policy is to provide the requested information.

Links to Other Services


You may be able to access third-party websites and services through links available on Buro’s Services.

Any links are provided for Your convenience. Buro does not have any control over those third-party websites or services and Buro does not provide any guarantee that the privacy practices of the hosts of those websites or services meet Buro’s standards. Your use of such third-party websites or services is at Your own risk and will be governed by the privacy policies of those websites or services and not by this Privacy Policy. Do not transmit Personal Information using those websites or services without reading the privacy policies governing those websites and services.

NOTE that You may choose to log-in to or register for Buro’s Services through social media online services (e.g., Facebook). When You do so, Personal Information from Your social media service account may be shared with Buro. The information Buro may receive varies by such services and is controlled by that service. By associating an account managed by a third party with Your Buro account and authorizing Buro to have access to this information, and You agree that Buro may collect, store, and use this information in accordance with this Privacy Policy. Buro is not responsible for how those third parties use and share Your Personal Information. Please refer to those third parties’ privacy policies to understand how they use and share Your Personal Information.

You may create links between Buro’s Services and social media online services. If You do so, Buro may be able to publish updates about Buro’s Services to Your social media service accounts through the links that You establish. You may terminate those links at any time by modifying Your social network account.

You may change the way social media services and Buro’s Services interact by modifying Your privacy settings in Your social media account. You can also log-out of Your social media account before using Buro’s Services. For more information, please refer to Your social media services’ privacy policy, which governs Your use of these features.


Storage Outside of Canada


Your Personal Information will not be used or stored by Buro or Buro’s service providers outside of Canada. Buro requires that Buro’s service providers safeguard Your Personal Information.

Children and Minors


Buro’s Services are not directed to children under the age of 18 years. Buro will not knowingly collect Personal Information about a child under the age of 18. Buro does not allow minors (persons who are under the age of majority in their place of residence) to create accounts, or lent or rent any items via the Services. Without such minors having the express consent of their guardian or parents.

How can I Access my personal Information ?


Upon request, Buro will provide You information regarding the existence, use and disclosure of Your Personal Information and You will be given access to that information. Buro will respond to an application for individual access to Personal Information within a reasonable time and at minimal or no cost to the individual. You may challenge the accuracy and completeness of the information and have it amended as appropriate.

NOTE: In certain circumstances, Buro may not be able to provide access to all of Your Personal Information that it holds. Exceptions may include information that is prohibitively costly to provide, information that contains references to 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. Buro will provide the reasons for denying access upon request.

Safeguards

Buro protects Your Personal Information by security safeguards appropriate to the sensitivity of the information. Buro will protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification.

Buro’s methods of protection include:

  1. Buro’s methods of protection include:

    • Physical measures, such as filing cabinets which are kept locked when not in use and restricted access, both to Buro's place of business in general and to internal offices as well;
    • Organization measures, such as security clearances and limited access on a need to know basis; and
    • Technological measures, such as the use of passwords, firewalls and encryption.

Inquiries; Challenging Compliance

Buro protects Your Personal Information by security safeguards appropriate to the sensitivity of the information. Buro will protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification.

Buro will maintain procedures for addressing and responding to all inquiries or complaints from Buro’s Users about Buro's handling of Personal Information. Buro shall investigate all complaints. All inquiries or complaints involving Buro's handling of Personal Information or compliance with this Privacy Policy or with PIPEDA shall be directed to Buro's Privacy Officer.

The Privacy Officer will respond to all such inquiries or complaints within 14 business days of receipt. The Privacy Officer will make reasonable efforts to resolve all such complaints within 30 days of receipt of the initial complaint. If Buro finds a complaint to be justified, it will take appropriate measures, including, if necessary, amending its policies and procedures.

For more information, please contact Buro’s Privacy Office as follows:
Email: contact@justburo.com
Mail: Buro Privacy Officer 439 University Ave Suite 780, Toronto, ON M5G 1Y8

General

Buro reserves the right to modify and amend this Privacy Policy from time to time in its sole discretion without prior notice. Any such amendment(s) will be posted on Buro’s Services and will be effective as of the date of posting.