Privacy Policy

Overview

We work hard to earn your trust. A big part of that is telling you what we do with your data. This privacy notice describes the personal data we collect, how it’s used, shared, and protected, as well as the data choices available to you.

Some of our products and services have their own privacy notices. If this notice is different than a privacy notice for a specific product, service, or type of data, the more specific privacy notice applies.

How we collect data

We collect data about you in different ways:

Directly from you. For example, when you register for an account or provide marketing or communications preferences.
Automatically.  For example, when you interact with our websites, use mobile applications on GSN devices, or use a device connected to the GSN network.
From other sources. For example, from our business partners, our vendors, and other third parties. This includes social media companies, financial institutions, and credit reporting agencies.
From ourselves. We may create data about you. For example, we may infer the types of services you might like or that you’re looking for a new device.

Data we collect & how we use it

Here are examples of the most common contexts in which we collect and use data.

Accessibility services and technologies

Examples of personal data collected

We collect data about how you use or access telecommunication relay services (TRS) and other accessibility-related services and adaptive technologies. This may include information about potential disability status (e.g., hard of hearing) and calling and billing preferences.

Primary purpose for collection and use

We use this data to provide telecommunication services and other accessibility-related services and adaptive technologies to individuals with disabilities. We may be legally required to collect and keep data about an individual’s disability status when we provide these services.

Account creation & billing

Examples of personal data collected

We collect your name, contact, and billing information when you create an account. We also collect information about the things you do while logged into your account (e.g., changes you make to your account).

Primary purpose for collection and use

We use this data to manage your account, including to process payments, billings, and requests related to our products and services. We also use this data to process requests related to third-party products and services that you charge to your accounts.

Analytics and Reporting

Examples of personal data collected

We collect data about how you use your GSN device, such as network diagnostic information, app usage data like how long the apps are open and how often you open an app. We may also use other data that you provided to us (e.g., age range, gender, etc.).

Primary purpose for collection and use

We aggregate this data to look for patterns to better understand your interests, behaviors, and trends. Aggregate reports may be used by GSN.

Audio recordings

Examples of personal data collected

We may record telephone calls with customer service or sales representatives.

Primary purpose for collection and use

We use this data for security and fraud detection. We also use this data to improve our customer service and sales experience.

Third-party authentication and fraud prevention

Examples of personal data collected

We may collect personal data like your name, address, phone number, account status, SIM change history, device status, and risk scores based on that information.

Primary purpose for collection and use

We use and may share this data with partners that help authenticate you with third parties such as your bank or other merchants you do business with, and for fraud prevention purposes.

Customer Proprietary Network Information

Examples of personal data collected

We collect data about your use of our voice services, like the type, location, destination, and amount of voice calling you use.

Primary purpose for collection and use

We use this data to run and maintain our network, manage your subscription, identify offers for GSN calling plans, protect against fraud, and respond to emergencies.

Demographics

Examples of personal data collected

This might include things like your age, job title, interests, where you live, or other characteristics about you.

Primary purpose for collection and use

We use this data to understand our users and provide tailored products, services, and offers.

Determining eligibility

Examples of personal data collected

We may collect data from you, financial institutions, or credit reporting agencies for eligibility purposes.

Primary purpose for collection and use

We use this data to verify your identity and decide your eligibility for accounts, discounts, and specific rate plans, as well as the validity of your payment information.

Extending credit or financing a phone

Primary purpose for collection and use

We may collect data from you, financial institutions, or credit reporting agencies to extend you credit or finance a device.

Internet of Things (IoT)

Examples of personal data collected

We may collect data from an IoT device if it’s connected to our network. If the IoT device is offered by another company (like a connected car), we may only collect basic communication meta data about what is flowing over our network with limited access to the communication content.

If you’re a customer of a GSN IoT service, we collect data to support the device. So, the type of data we collect will vary depending on the type of device and service. This could include contact information, location, audio, video, and device activity and measurement data. See the documentation for your specific IoT device and service for more information.

Primary purpose for collection and use

We use this data to provide connectivity to IoT devices offered by third parties, and to provide our own IoT services.

Legal purposes

Examples of personal data collected

Various personal data described in this section of this privacy notice.

Primary purpose for collection and use

We use personal data to cooperate with law enforcement, comply with legal and regulatory obligations, respond to government requests, and to enforce and comply with our agreements. We also use personal data to help calculate taxes, fees, or other obligations due to local, provincial, or federal government requirements.

Order placement

Examples of personal data collected

We collect your name, billing address, shipping address, email address, phone number, and credit card number when you place an order.

Primary purpose for collection and use

We use this data to provide you with our products or services.

Our emails

Examples of personal data collected

If you receive an email from us, we may capture data related to when you open our message or click on a link.

Primary purpose for collection and use

We use this data to understand how you interact with our communications to you.

Product development & personalization

Examples of personal data collected

Various personal data described in this section of this privacy notice.

Primary purpose for collection and use

We use personal data to provide, develop, customize, and personalize products and services, including to train artificial intelligence models (e.g., to improve our network, enhance customer service, etc.).

Public reviews

Examples of personal data collected

We may allow you to post comments or reviews about product purchases.

Primary purpose for collection and use

We use this data to share reviews with the public.

Quality assurance

Examples of personal data collected

Various personal data described in this section of this privacy notice.

Primary purpose for collection and use

We use personal data to help maintain and improve the quality and safety of our products and services, including to enforce our policies. We also use personal data to conduct research and create reports from analysis of usage patterns and trends.

Authentication, fraud prevention, security, and safety

Examples of personal data collected

We collect data such as your government identification (like a driver’s license or passport), Social Insurance Number, photos of your face, biometric information (like a face scan), security code, signature, account data, and network data.

Primary purpose for collection and use

We use this data to secure your account, verify your identity, and detect and prevent fraud. We also use personal data described in this section of the privacy notice to protect the rights, interests, safety, or property of GSN, you, and others, including to detect and help protect against security incidents and other unauthorized activities.

Support and feedback

Examples of personal data collected

If you provide us feedback or contact us for support, we will collect your name and email address, and any other content you send to us.

Primary purpose for collection and use

We use this data to receive and act upon your feedback or issues. We also may use personal data described in this section of this notice to respond to your inquiries.

Surveys

Examples of personal data collected

We collect data you provide through surveys. If a survey is provided by a third party, the third party’s privacy notice applies to the collection, use, and disclosure of your data.

Primary purpose for collection and use

We use this data to understand your opinions and collect information relevant to our organization.

Sweepstakes or contests

Examples of personal data collected

When you enter a sweepstakes or contest, we collect your contact information.

Primary purpose for collection and use

We use this data to run the sweepstakes or contest and may also use it to market to you. Sometimes the law requires us to collect data about those that enter into our sweepstakes.

Your location

Examples of personal data collected

When you use a device on our network, we collect data about where you are.

Primary purpose for collection and use

We use location data to provide and support our services, including to route wireless communications, run and improve our networks and business, detect and prevent fraud, help emergency responders, or comply with legal obligations.

Your device usage

Examples of personal data collected

We collect data about how you use our network. This might include IP addresses, text messages, data usage, websites and URLs visited, viewing information from streaming services, and mobile applications you have installed on your phone.

Primary purpose for collection and use

We use this data to better understand you, detect and prevent fraud, to recommend apps to you, improve our network and troubleshoot issues, and to provide products and services.

Your use of our websites and mobile apps

Examples of personal data collected

We use technology to monitor how you interact with our websites and mobile apps. This may include which links you click on, and in what order, or information that you type into our online forms.

Some of these technologies may use “cookies.” Cookies are small pieces of information that a website sends to a computer’s hard drive while a website is viewed.

Other types of data we track include your IP address, the website that referred you to our website, and data about the device you use to visit our website.

Primary purpose for collection and use

We use this data to make our websites and apps run efficiently. We also use it to understand how you interact with our websites and apps to improve them, understand your preferences, and help select GSN offers that you might find most useful. Finally, we use this information to help detect and prevent fraud.

Sensitive Data Disclosure. We collect the following categories of sensitive personal data (as defined under certain provincial privacy laws): your Social Insurance Number, driver’s license, government-issued identification card, or passport number, your account log in, financial account information, debit or credit card number in combination with any required security or access code, password, or information allowing access to an account, your precise location, what is in your text messages, biometric data, and children’s data. There may also be times when we’re able to see your citizenship or immigration status, such as when you use a visa or passport for identification. And there may be times when we’re able to see that you were the victim of a crime, such as when you provide us with a police report about the theft of your device. We only use it for things like providing services, processing transactions, complying with laws, managing our business, preventing fraud, harm, or other illegal actions, and securing your data and our network.

De-identified Data. We may de-identify, aggregate or anonymize personal data or collect data that has been de-identified, aggregated, or anonymized. We don’t try to re-identify this data (i.e. re-associate it with an individual person), except as necessary to evaluate the effectiveness of our de-identification policies and procedures.

How we share data

Here are the general categories of personal data we disclose for a business purpose. We do not knowingly share the personal data of minors under 18 years of age.

Identifiers

This may include real name, postal address, unique personal identifier, online identifier, email address, account name, or other similar identifiers.

Who we disclose this data to for a business purpose

Data analytics providers
Internet service providers
Operating systems and platforms
Payment processors and financial institutions
Other service providers

Government-issued identification

This may include Social Insurance Number, driver’s license number, or state issued identification number, passport number.

Who we disclose this data to for a business purpose

Service providers

Financial information

This may include bank account number, credit card number, debit card number, and other financial information.

Who we disclose this data to for a business purpose

Operating systems and platforms
Payment processors and financial institutions
Other service providers

Characteristics of protected classifications under provincial or federal law

This may include things like age.

Who we disclose this data to for a business purpose

Payment processors and financial institutions
Other service providers

Commercial information

This may include information about products or services bought, obtained, or considered, or other purchasing or consuming histories or tendencies.

Who we disclose this data to for a business purpose

Data analytics providers
Internet service providers
Operating systems and platforms
Payment processors and financial institutions
Other service providers

Biometric information

This may include information about your physical or biological characteristics (like face scans and voiceprints) where they are used to identify you.

Who we disclose this data to for a business purpose

Service providers

Internet or other electronic network activity information

This may include browsing history, search history, phone usage data, and information about an individual’s interaction with an internet website, application, or advertisement.

Who we disclose this data to for a business purposeData analytics providers

Internet service providers
Operating systems and platforms
Other service providers

Location data (general and/or precise)

This includes types of sharing that only happen if you give us permission.

Who we disclose this data to for a business purpose

Data analytics providers
Internet service providers
Payment processors and financial institutions
Other service providers

Audio, electronic, visual, or similar information

Who we disclose this data to for a business purpose

Data analytics providers
Internet service providers
Other service providers

Inferences drawn from any of the personal data categories described above

Who we disclose this data to for a business purpose

Data analytics providers
Internet service providers
Operating systems and platforms
Payment processors and financial institutions
Other service providers

Your choices

We offer you certain choices related to your personal data:

Access. You may request access to your personal data or confirmation that we have data about you. We will provide access to your data in a portable and machine-readable format. For multi-line accounts, the individual in charge of your account that submits an access request will receive account-level data for all lines on the account (e.g., billing and rate plan information). Personal data associated with a particular phone number on the account will not be shared with them. If you’re not in charge of the account, you’ll only see data that is associated with your phone number.
Analytics and Reporting. You may opt out of having the data from your GSN device aggregated as part of our Analytics and Reporting program.
Changes. Most of our websites allow you to change your account profile. For changes that can’t be made through your account profile, you can request that we correct your personal data.
Deletion. You may request that we delete your personal data. Note that in many situations we must keep some of your personal data for our business purposes, like providing service to you, detecting security problems, or complying with our legal obligations.
Marketing emails or texts. You can adjust your marketing communication preferences.
Profiling and automated decisions. You can tell us not to use your personal data for certain kinds of “profiling” that we might do in the future. “Profiling” is a specific type of activity under certain privacy laws and generally refers to the automated processing of personal data to evaluate, analyze, or predict certain personal aspects about your performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements. You can opt out of having profiling used for future decisions that produce legal or similarly significant effects on you.

These choices may not apply in every circumstance. In some cases, we might limit or deny your request because the law allows or requires us to do so. We might also deny your request if we can’t verify who you are. We won’t discriminate against you for making one of these choices.

We’re required to verify your identity before we can give you access to, change, or delete your personal data. So, you’ll need to provide some data for us to do the verification. This includes your email address and phone number, or your GSN ID and password. If you don’t have a GSN ID, you may need to provide your Canadian driver’s licence or passport. We may also need a photo of your face so we can ensure the photo ID belongs to you. In some cases, you may designate an authorized agent to submit requests on your behalf.

If you disagree with our denial of a request, you may be entitled to submit an appeal. If that’s the case, we’ll include instructions for how to submit your appeal in our response.

How we protect data

Our cybersecurity program is continuously working to help keep personal data safe and to maintain secure systems and products. We monitor performance, invest in our digital infrastructure, and leverage industry best practices to identify and assess cybersecurity threats. We use independent experts and security researchers to test our cybersecurity defenses and help identify potential weaknesses. And we provide employees with the tools and training needed to help protect our systems and data.

How long we keep data

We strive to keep your personal data for only as long as necessary to fulfil the purposes outlined in this notice unless a longer retention period is required or allowed by law. To decide how long to keep personal data, we consider things like:

The amount, nature, and sensitivity of the data.
The potential risk of harm from unauthorized use or disclosure of the data.
The purposes for which we obtained the data.
Whether we can achieve those purposes through other means.
Applicable legal, accounting, or reporting requirements.

Other information

Third-party applications and websites
We may provide links to websites and other third-party content or services that we do not own or operate. The websites and third-party content we link to may have separate privacy notices or policies. We have no control over the privacy practices of websites or services that we do not own. We encourage you to review the privacy policies of any third-party website or application for details about their privacy practices.

Consumer health data privacy notice

Our collection and use of consumer health data
Some types of data we collect could also be considered consumer health data, as that term is sometimes broadly defined. Read below for examples of data we collect that may be considered consumer health data, the sources of that data, and the purpose(s) for which that data is collected and used. We collect these types of data to do things like provide and improve your GSN products and services. We may disclose your consumer health data to our service providers or where we’re required to comply with legal and regulatory obligations.

Biometric data (verification)

This may include information about your physical or biological characteristics (like face scans and voiceprints) where they are used to identify you.

Sources of data we collect

Photos of your face and scans from the identification (ID) you provide us to verify your identity online.

Primary purpose for collection and use

To verify your identity and for fraud prevention purposes.

Device and network data
We collect data when you use a device connected to the GSN network (as part of providing you the products and services you select), including where you are when you use a device on our network, phone numbers called/texted, IP addresses, websites and URLs visited, and when you install or use mobile applications on GSN devices. We do not use this data to create consumer health data inferences about you.

Your consumer health data choices
You may have some rights to your consumer health data, including the right to access your consumer health data, the right to ask us to delete your consumer health data, and the right to withdraw any consumer health data opt-in consents you may give us.

Changes to this privacy notice

We may change our notice and privacy practices over time. This notice includes a “last updated” date which is the date the current version was last changed.

If you have any questions or concerns about our privacy practices, or if you need to access this notice in a different format, please contact us using the information below.