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Our Privacy Commitment to You

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Our Privacy Commitment to You Our privacy commitment to you At Koodo, we respect our customers’ privacy and take great care to safeguard personal information. As part of our ongoing commitment to putting customers first, we have a long-standing policy of protecting privacy in all of our business operations.1 We believe that an important part of protecting privacy is to be clear about how we handle customers' personal information, and to make information about our approach easily accessible. While our Privacy Code sets out the general principles that govern the collection, use and disclosure of our customers’ personal information2, we have also developed this Privacy Commitment to provide you with more specific details about our privacy practices.3 We have learned from our customers that sometimes you just want the big picture, while other times you may want more details or examples of how a policy or process works. For this reason, we have structured this Privacy Commitment in layers. Importantly, both our Privacy Code and Privacy Commitment reflect the requirements of Canada’s applicable privacy legislation, including the Personal Information Protection and Electronic Documents Act, applicable Canadian Radio-Television and Telecommunications Commission (CRTC)v privacy regulations, and our own continuing commitment to customer privacy. The bottom line is that we want you to understand the purposes for which we collect, use and disclose personal information about our customers. The following is a summary of our privacy practices. Why we collect personal information When we share personal information Some of the ways we respect your privacy Choices we offer you Questions? 1 Why we collect personal information If you are a Koodo customer, Koodo collects certain information about you. We respect your privacy, which is why we collect personal information only for the following purposes: To establish and maintain To understand your needs and To develop, enhance, market a responsible commercial preferences. or provide products and relationship with you and to services. Here are some examples of what we provide ongoing service. mean by this: Here are some examples of what we Here are some examples of what we mean by this: We maintain a record of the products mean by this: • and services you receive from From time to time, we may review When you apply for a service, we us, and we may collect additional • and analyze your use of our products • generally set up an account and information about the usage levels and services to help us provide collect information such as name, and patterns associated with those better product recommendations address, date of birth, preferred products and services. and special offers that we think will language, Koodo account number(s), Some of the data we collect or use interest you. any other authorized users, unique • for this purpose includes your We may examine your wireless account security PIN(s) and email wireless device information, such as • calling patterns in order to address. telephone number, SIM card number, recommend a new monthly plan that • In order to confirm your identity and/ operating system, network type, saves you money. or conduct a credit check, we may manufacturer, model and make, and We may analyze your use of our also ask for acceptable identification IMEI serial number. • products and services to better or identifying information. We may also collect additional understand your preferences, and We also collect and use some • information so that we can better to help us develop or enhance our • personal information to confirm meet your needs and preferences, products and services. This may your identity when you contact us. including details of the products and include analysis of location data to For example, when you call us, we services you receive from us, such as provide relevant, new or enhanced will ask to confirm some personal your wireless device rate plan. products and services. For example, information to verify it’s actually you We may collect or infer information if you are roaming outside of the and not someone trying to access • about you or your preferences for Koodo network with your wireless your account without authorization. particular products, services or device, we may offer you a roaming For billing purposes, we collect lifestyle activities from information package. • records of the services you use, you provide us about yourself when We might recommend a new service such as telephone numbers, times, you tell us your preferences, or when • or one of our apps that we think dates, and durations of incoming your usage activities indicate what you’ll enjoy based on your existing and outgoing calls. We also collect your preferences are. services with us or the apps you use. payment information to set up pre- We note that our customers who do authorized payments if you choose not wish to receive these types of to do so. recommendations or offers may choose To assist you in understanding your to be removed from our marketing lists • bill, we also collect information about at any time. how the services or apps used on any of the devices on your account contribute to data usage. 2 To manage and develop our are assigned, have connected to, To meet legal and regulatory business and operations. or attempted to connect to. This requirements. allows us to continue offering Here are some examples of what we Here are some examples of what we Internet connectivity. mean by this: mean by this: We may use video surveillance to We may collect personal information • We may collect or preserve • monitor and/or record the activity • to help us manage our day-to-day that occurs around our stores, information in response to a court operations efficiently, and to manage premises or infrastructure, including order, which may include collecting our infrastructure, including securing wireless sites. We may also use your wireless device location for it and planning for future growth. unmanned air vehicles (drones) specific purposes. We analyze how many customers to inspect our remote wireless or For example, when you dial 911 and • use our wireless sites at what network sites (i.e., cell towers). This • we provide GPS and triangulation times of the day to help us plan information is used to maintain data to the 911 operations centre. our networks, or for security and new infrastructure. We also look There is certain information investigation purposes to protect us at records associated with text • that we are required to collect, from theft, vandalism or damage to and multimedia messages - which use and disclose as a regulated our property. includes the date and time of sent telecommunications company. For and received messages, but not We monitor activity on our networks example, if a customer dials 911, the content itself, as well as the • to detect and prevent fraud to we provide the customer’s name, associated phone numbers and protect both our customers and telephone number, and location cell towers. our business. information to the emergency • We similarly analyze records We record interactions, such as agency. Another example would be associated with calls made on • telephone calls or chats, to or to satisfy a request for information our cellular network, including from our service representatives from the Canadian Radio-Television location data (i.e., locations of for quality assurance and training and Telecommunications the cell towers that handled purposes; our systems may also Commission (CRTC) about a the communications). This conduct real-time analytics on such customer complaint and how it also helps us plan for future interactions to identify trends and was resolved. infrastructure investment. patterns to help us serve you better. • We need to collect certain • We may look at usage data on our We collect information about information to comply with statutory high-speed Internet network to help • visits to our websites (such as obligations, including our tax us improve reliability and stability. koodomobile.com) to optimize our reporting obligations. We collect and use IP addresses and web properties, and for security port numbers that our customers purposes. 3 When we share personal information We take great care with what information we share, and why. There are circumstances where we share some personal information about our customers: To facilitate and improve the To enable our service For emergency purposes. provision of products and providers and partners to We may share information with a public services to you. help us serve you better. authority or agent of a public authority if, Here are examples of what we mean We may share information with our in the reasonable judgment of Koodo, it by this. We may share personal suppliers, agents or other organizations appears that there is imminent danger to information with: or individuals contracted to us to perform the life, health or security of an individual services or functions on our behalf where which could be avoided or minimized by a person seeking information as they require the information to assist disclosure of the information. • an agent of a customer, such as a us in serving you. We strive to minimize customer’s legal representative, or as the amount of personal information an authorized user under his or her Where required by law or that we share with our service providers account, if we are satisfied that the applicable regulation. and partners; we share the information person is authorized to receive the reasonably necessary to achieve the We share customer personal information information; stated purpose, and require that it only with law enforcement or other other TELUS business units to help be used to achieve that stated purpose. government agencies if we are required • us serve our customers better and to do so to meet legal and regulatory to provide them with services from Examples of what we mean by requirements; for example, if we are different parts of our company; service providers or partners include required to provide records to law organizations that: enforcement in response to a valid court another telecommunications • Conduct research on our behalf, such order.
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