MBITIR SOFTWARE INC.
Registered Address: 40 Holm Crescent, Thornhill, Ontario, L3T 3B3, Canada
Last Updated: March 2026
Effective Date: March 2026
This Privacy Policy (the “Policy”) sets out how MBITIR SOFTWARE INC. (“we”, “us”, “our”) collects, uses, discloses, retains and protects personal information (as defined below) in the course of our commercial activities, including our core business of APP application download promotion, software development, digital technology services and related operations. This Policy is drafted in compliance with the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable privacy laws and regulations of the Province of Ontario, Canada, and adheres to the 10 Fair Information Principles under PIPEDA.
By accessing or using our websites, services, products, or engaging in any business interaction with us (collectively the “Services”), you consent to the collection, use and disclosure of your personal information in accordance with this Policy. If you do not agree with the terms of this Policy, please do not use our Services.
Applicable Law
This Policy shall be governed by and construed in accordance with the laws of the Province of Ontario and the federal laws of Canada applicable therein, without regard to its conflict of law principles.
Definition of Personal Information
For the purposes of this Policy, personal information means any information about an identifiable individual, including but not limited to your name, email address, mailing address, telephone number, company name, job title, device identifiers, IP address, payment information and any other information you voluntarily provide to us.
Information that is not associated with an identifiable individual (e.g., anonymous statistical data about website traffic, aggregated user behavior data) and the business contact information of an organization’s employees (e.g., business address, office phone number) are not considered personal information under this Policy.
Accountability
We are responsible for all personal information under our control and have designated a privacy representative to oversee compliance with this Policy and applicable Canadian privacy laws. Our privacy representative is responsible for responding to your privacy-related inquiries, requests and complaints.
Purposes of Collecting Personal Information
We collect personal information only for the following legitimate business purposes, which we identify to you at or before the time of collection:
To provide and fulfill our Services, including APP download promotion, software technical support, customized solution development and transaction processing;
To communicate with you, respond to your inquiries, requests, feedback and provide customer service;
To process and verify your identity, create and manage your account (if applicable);
To send you important updates about our Services, including changes to terms, service announcements and security alerts;
To improve our Services, analyze user behavior and optimize our website and operational performance through anonymous analytics;
To comply with our legal and regulatory obligations under Canadian federal and provincial laws;
To protect our legitimate business interests, including preventing fraud, unauthorized access and other illegal activities.
We will not collect personal information for any undisclosed or unrelated purposes without your prior consent.
Collection of Personal Information
4.1 Voluntarily Provided Information
We collect personal information that you voluntarily provide to us through various channels, including but not limited to:
Completed forms on our website (e.g., contact forms, quote requests, support requests);
Direct communications with us (e.g., emails, phone calls, chat messages);
Account registration and sign-up processes for our Services;
Participation in our surveys, promotions or other business activities;
Provision of payment information for our paid Services.
4.2 Automatically Collected Information
When you access our website or use our online Services, our servers may automatically collect certain non-identifiable or aggregated information about your device and usage patterns, including:
Internet Protocol (IP) address of your device;
Operating system, browser type and Internet Service Provider (ISP);
Pages visited, date and time of access and navigation paths on our website;
Files requested and website traffic statistics.
This information is collected only for analytics purposes to improve our website and Services, and we do not link it to your personal identity unless required by law.
4.3 Limitation on Collection
We collect only the personal information that is necessary and minimal to achieve the identified purposes set out in Section 3. We do not collect sensitive personal information (e.g., medical records, financial information, racial or ethnic origin) unless required for our Services and with your express consent.
Consent
5.1 Obtaining Consent
Knowledge and consent are required for the collection, use or disclosure of your personal information, except where required or permitted by Canadian law (e.g., fraud investigation, compliance with a court order).
Your consent may be express (e.g., written, oral, electronic submission of a form) or implied (e.g., using our Services after being informed of this Policy, providing personal information for a clear business purpose). For the collection, use or disclosure of sensitive personal information, we will obtain your express consent.
5.2 Withdrawal of Consent
You may withdraw your consent to the collection, use or disclosure of your personal information at any time, subject to legal or contractual restrictions. To withdraw your consent, please contact our privacy representative using the contact information set out in Section 12.
Withdrawal of consent may limit our ability to provide you with certain Services. We will process your withdrawal request in a timely manner in accordance with applicable laws.
Use and Disclosure of Personal Information
6.1 Limitation on Use
We use your personal information only for the purposes for which it was collected, as set out in Section 3, unless we obtain your additional consent or are required by law to use it for other purposes.
6.2 Limitation on Disclosure
We will not disclose, sell, rent or share your personal information with third parties, except in the following circumstances:
With your prior consent;
To our trusted service providers who perform services on our behalf (e.g., payment processors, IT service providers, marketing partners), and who are bound by confidentiality obligations and prohibited from using the information for any other purpose;
To comply with applicable Canadian federal or provincial laws, regulatory requirements or a valid court order;
To protect our legitimate business interests, including investigating and preventing fraud, unauthorized access, or other illegal activities that may harm us or our users;
In connection with a business transaction (e.g., merger, acquisition, sale of assets), where personal information may be transferred as part of the transaction (the transferee will be bound by this Policy).
6.3 Cross-Border Data Transfer
If your personal information is transferred outside of Canada for the purposes set out in this Policy, we will take appropriate contractual and technical safeguards to ensure that the information is protected in accordance with PIPEDA and applicable Canadian privacy laws, and that the recipient adheres to equivalent privacy protection standards.
Retention of Personal Information
We retain your personal information only for the period of time necessary to fulfill the purposes for which it was collected, or as required by applicable Canadian federal or provincial laws and regulations.
Once the retention period expires, we will securely delete, destroy or anonymize your personal information to prevent unauthorized access or use.
Accuracy of Personal Information
We take reasonable steps to ensure that your personal information is accurate, complete and up-to-date for the purposes for which it is used.
You have the right to request access to and correction of any inaccurate or incomplete personal information we hold about you. To make a correction request, please contact our privacy representative using the contact information set out in Section 12.
Safeguards for Personal Information
We take reasonable and appropriate technical, administrative and physical safeguards to protect your personal information from loss, theft, unauthorized access, disclosure, alteration or destruction, commensurate with the sensitivity of the information. Our safeguards include but are not limited to:
Secure server storage and encryption of personal information;
Access controls and password protection for systems containing personal information;
Regular security training for our employees;
Confidentiality agreements with our employees and third-party service providers;
Regular security audits and updates to our privacy and security practices.
While we take all reasonable precautions to protect your personal information, no electronic storage or transmission is 100% secure. We cannot guarantee absolute security of your personal information, and you provide information at your own risk.
Openness
We make this Policy readily available to all individuals who interact with our Services. This Policy is posted on our website (if applicable) and we will provide a copy of this Policy to you upon request.
We will review and update this Policy periodically to reflect changes to our privacy practices or applicable Canadian privacy laws. Any material changes to this Policy will be posted on our website (if applicable) and the “Last Updated” date at the top of this Policy will be revised. Continued use of our Services after the effective date of the revised Policy constitutes your consent to the changes.
Individual Access to Personal Information
Pursuant to PIPEDA, you have the right to request:
Confirmation of whether we hold personal information about you;
Access to the personal information we hold about you;
Information about the purposes for which the personal information is used and disclosed.
To submit an access request, please contact our privacy representative using the contact information set out in Section 12. We may require proof of your identity to process your request, and we will respond to your request within the time limits prescribed by Canadian law (typically 30 days). We may charge a reasonable administrative fee for processing complex or repeated access requests, as permitted by law.
Challenging Compliance
If you have any questions, concerns, feedback or complaints about this Policy, or wish to submit a request for access, correction, withdrawal of consent or deletion of your personal information, please contact our privacy representative at:
Mailing Address: 40 Holm Crescent, Thornhill, Ontario, L3T 3B3, Canada
Email: [[email protected]] (replace with actual email address)
Phone: [+1 (XXX) XXX-XXXX] (replace with actual phone number)
We will investigate and respond to your privacy-related inquiries and complaints in a timely and fair manner. If you are not satisfied with our response, you have the right to file a complaint with the Office of the Privacy Commissioner of Canada (OPC).
Third-Party Websites and Services
Our website and Services may contain links to third-party websites, products or services that are not owned or controlled by us. This Policy does not apply to such third-party websites or services, and we are not responsible for the privacy practices or content of third parties.
We encourage you to review the privacy policies of any third-party websites or services you access through our Services before providing any personal information.