1. Our Privacy Philosophy

This privacy policy (the “Policy”) explains how Karibu Solutions Inc. and its subsidiaries (collectively, “Karibu”, “we”, or “us”) collect, use, disclose and safeguard the personal information that you or a third party provide. We have adopted this Policy to affirm our commitment to maintaining the accuracy, confidentiality, and security of personal information. Providing personal information or authorizing a third party to disclose personal information to us signifies your consent to Karibu’s collection, use and disclosure of personal information in accordance with this Policy. If you provide personal information to us about a third party or authorize a third party to disclose personal information to us, you agree that you were authorized to do so.

For the purposes of this Policy, “personal information” means information that can identify an individual directly or through other reasonably available means. “Personal information” does not include information that is used for the purpose of communicating or facilitating communication with an individual in relation to their employment, business, or profession. Notwithstanding anything to the contrary herein, the meaning of “personal information” shall be interpreted in a manner that conforms with the minimum requirements of applicable privacy legislation.

2. Identifying Purposes and Obtaining Your Consent

We identify the purposes for collecting personal information at or before the time it is collected. We will not collect, use or disclose your personal information without your informed consent, unless required or permitted to do so by law.

At Karibu, we collect and use personal information so we can:

  • (i) provide, maintain, and improve our products and services, which includes using the information to verify your identity, process payments, allocate resources, offer healthcare, reporting, and translation services, and otherwise run and manage our business in the ordinary course;
  • (ii) provide information to our employees, contractors, and affiliates to allow them to perform services on our behalf, including the provision of personal information to service providers engaged by Karibu;
  • (iii) send you newsletters or other communications to which you have subscribed or may be interested;
  • (iv) comply generally with privacy laws and all other applicable regulatory requirements;
  • (v) understand the demographics, interests, usage patterns, and other characteristics of migrant workers and to track and analyze trends and patterns, including through the aggregation of personal information;
  • (vi) administer surveys, contests, draws, and raffles;
  • (vii) offer you tailored content, including advertisements and promotions; and
  • (viii) assist you when you contact our customer support services, including to direct your questions to appropriate individuals, investigate and address any of your concerns, and to improve and monitor our customer support responses. We may also use your personal information for purposes that are otherwise consistent with the terms of this Policy or that are permitted or required by law, and for purposes for which you have otherwise provided consent.

Should we require your information to fulfill a purpose that is not identified in this Policy, we will obtain your consent before proceeding.

3. Limiting the Collection, Use and Disclosure of Your Personal Information

(a) The information we collect

The type of personal information that we may collect, including when you register for an account or use our Website (as defined below) or our applications, includes:

  • (i) your name, mailing address, email address, telephone number, employer, and employment details;
  • (ii) other information that you share in your communications with us, our employees, our contractors, or third parties providing services through our website (including through our healthcare partners and our reporting tool) including on or through our website https://karibusolutions.com/ or any other websites operated by Karibu (collectively, the “Website”) and our applications.

The choice to provide us with your personal information, either directly or through a third party, is yours. However, your decision to withhold particular information may limit our ability to provide you with some of our products or services.

If you report information about your working conditions through the Website or our applications, we are not able to access the report ourselves without your express consent.

(b) How your information is collected

Personal information may be collected in a number of ways, including: in person, over the phone, by mail, by fax, over the Internet (including from our Website, by email, or through any of our applications or other software that we provide), and from third parties whom you have authorized to disclose personal information to us.

We may collect usage information from users of our services, including through the use of cookies, web beacons and tracking pixels, SDKs, and other similar technologies. Cookies are very small text files that are stored on your browser or device. Usage information collected from our Website and our applications may include your device type, device identifier, IP address, MAC address, location, browser type, operating system, duration of use, user behaviour, length of time spent on the services, and frequency of use. We may use this information for purposes including remembering your preferences and settings, determining the popularity of certain content, authenticating users, determining the effectiveness of any advertising campaigns, and analyzing the behaviour and interests of people (including traffic and trends) accessing our Website and applications. We may also allow others to provide analytics services (e.g. Google Analytics) and audience measurement services for us, to serve advertisements on our behalf on the Internet, and to monitor and report on the performance of those advertisements. These third parties may perform such services through the use of cookies, web beacons and tracking pixels, SDKs, and other similar technologies. By modifying your browser settings, you may be able to block cookies or otherwise make adjustments to the use of cookies, although this may affect the functioning of certain Karibu services. You may also visit http://optout.networkadvertising.org/?c=1 to opt out of certain other cookies.

If you believe that a third party has inappropriately disclosed your personal information to us, please contact that third party directly. If the third party does not sufficiently respond to your inquiries, please let us know immediately.

Your personal information will only be used or disclosed in accordance with the purposes for which it was collected, unless you have otherwise consented or except where required or permitted by law.

(c) We may monitor and record telephone calls

For the purpose of maintaining quality service, telephone calls to our customer service lines may be recorded. If your call is subject to a quality assurance program, you will be so advised prior to speaking with a representative.

(d) Disclosure to third parties

We may share your personal information with our service providers in order for them to provide services to or on behalf of Karibu, including processing and storage. These may include, for example, cloud storage providers and data analytics providers. To that end, when you provide personal information to Karibu, the information may be stored on servers hosted or owned by a third party.

If you use a credit or debit card or other method of payment for your purchase, information with respect to your payment method is required to process your payment. We do not store your payment information. Your payment information will be provided directly to our third party payment provider.

We may

  • (i) share your personal information with our affiliates;
  • (ii) combine information internally across our affiliates or our different products and services;
  • (iii) combine personal information with demographic information, publicly available records and other third party information sources. We may use this information to provide you with a customized experience, to promote and develop products and services available through Karibu or its affiliates, or as otherwise permitted by this Policy.
  • If you post a review, make a comment, or otherwise submit personal information on a public forum such as social media accounts or public forums on our Website or other applications, your communications may be viewable by the public.

    We may also disclose personal information in situations where we are legally required or permitted to do so. The type of information we are legally required to disclose may relate to criminal investigations or government tax reporting requirements or to enforce your rights or to investigate suspicion of unlawful activities. In some instances, such as a legal proceeding or court order, we may also be required to disclose your personal information to authorities. Only the information specifically requested is disclosed and we take precautions to satisfy ourselves that the authorities that are making the disclosure request have legitimate grounds to do so. We may release certain personal information when we believe that such release is reasonably necessary to protect the rights, property or safety of ourselves and others.

    We may use and disclose your personal information to third parties in connection with the proposed or actual financing, insuring, sale, securitization, assignment or other disposal of all or part of our business or assets (including accounts) for the purposes of evaluating and/or performing the proposed transaction. These purposes may include, as examples, permitting such parties to determine whether to proceed or continue with the transaction, fulfilling any reporting or audit requirements to such parties, and/or disclosing personal information as part of concluding a sale or transfer of assets. Our successors and assigns may collect, use and disclose your personal information for substantially the same purposes as those set out in this Policy.

    If you use a platform that is integrated with our Website or our applications, then you may be asked to agree to the terms and conditions or privacy policy of that platform. At the time that you agree to these terms, you may also be asked to consent for Karibu to transfer personal information from Karibu to that platform for the purposes of allowing that platform to provide the requested services (e.g. virtual healthcare) to you.

    We may share Personal Information in the aggregate with third parties. For example, we may disclose the number of users that have been exposed to or clicked on advertisements. We may also disclose anonymized information about your use on Karibu. For example, if you engage in a transaction in connection with Karibu, we may publicly disclose information about the transaction in a manner that does not disclose Personal Information. This could include, for example, providing data to appropriate governmental authorities or nonprofit organizations on the number and type of reports about work conditions, so that the government can identify concerns about work conditions without your personal information being disclosed to the government.

(d) Keeping your information accurate

We make every reasonable effort to keep your personal information as accurate, complete and up-to-date as necessary. If desired, you may verify the accuracy and completeness of your personal information in our records.

Despite our efforts, errors sometimes do occur. Should you identify any incorrect or out-of-date information in your file, we will remedy any such errors on a timely basis. In the event that inaccurate information is mistakenly sent to a third party, we will communicate relevant changes to the third party where appropriate.

4. Protecting Your Personal Information

(a) Access to your information within Karibu

Access to private, sensitive and confidential information, including your personal information, is restricted to authorized employees or contractors with legitimate business reasons.

Our employees and contractors understand the importance of keeping your information private. All employees and contractors are expected to maintain the confidentiality of personal information at all times and failure to do so will result in appropriate disciplinary measures including dismissal.

(b) Disposal and Retention

Except as otherwise permitted or required by law, your personal information will be retained for so long as is reasonably necessary to fulfil the purposes for which it was collected.

(c) Safeguarding your information

To ensure that your personal information is protected, we utilize security safeguards that are on par with the industry standard. We keep electronic customer files in a secured environment with restricted access and use.

5. Addressing Your Inquiries and Concerns

We are happy to provide you with a copy of this Policy.

Upon request, we will also inform you of: the type of personal information we have collected, how your personal information has been used, and any third parties to whom your personal information has been disclosed.

Please direct all questions or enquiries about this Policy to:

Address: 65 Shirley Street, Toronto, ON, M5K 1T2

Email: 65 Shirley Street, Toronto, ON, M5K 1T2

6. Updating this Privacy Policy

Karibu strives to evolve to meet our customer’s needs and expectations, and that means our products and services may change, and how we offer our products and services may change. With that in mind, we review our privacy practices from time to time, and that our information handling practices may change. Any changes to our privacy standards and information handling practices will be reflected in this Policy in a timely manner. Karibu reserves the right to change, modify, add, or remove portions of this Policy at any time. Please check this page periodically for any modifications. To determine when this Policy was last updated, please refer to the modification date at the bottom of this Policy. If at any point you do not agree with the terms of this Policy, you must not use Karibu’s services.

7. Website and Apps Governed by this Privacy Policy

Our Website and any of our applications available from our Website or third party platforms (including the iTunes Store and Google Play) are governed by the provisions and practices stated in this Policy. Our Website and such applications may contain links to third party sites or applications that are not governed by this Policy. Although we endeavour to only link to sites or applications that share our commitment to your privacy, please be aware that this Policy will no longer apply once you leave our Website or such applications, and that we are not responsible for the privacy practices of third party sites or applications. We therefore suggest that you closely examine the respective privacy policies of third party sites and applications to learn how they collect, use and disclose your personal information.

8. Governing Law

This Policy and all related matters shall be interpreted and construed in accordance with the laws of the Province of Ontario and the applicable federal laws of Canada.

9. Personal Information Outside of Canada

Karibu may perform activities outside of Ontario and outside of Canada through third parties. For example, personal information provided to our payment processors may be stored outside of Ontario and outside of Canada. You acknowledge and agree that, as a result, your personal information may be processed, used, stored or accessed in other jurisdictions and may be subject to the laws of those jurisdictions. For example, information may be disclosed in response to valid demands or requests from government authorities, courts, or law enforcement in other countries.