Privacy Policy — Whollar

Summary of key points

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by clicking the link following each key point or by using the list of sections to find what you are looking for.

Privacy at a glance

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.

Do we process any sensitive personal information? Some of the information may be considered “special” or “sensitive” in certain jurisdictions, for example your racial or ethnic origins, sexual orientation, and religious beliefs. We may process sensitive personal information when necessary with your consent or as otherwise permitted by applicable law. Learn more about sensitive information we process.

Do we collect any information from third parties? We may collect information from public databases, marketing partners, social media platforms, and other outside sources. Learn more about information collected from other sources.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.

In what situations and with which types of parties do we share personal information? We may share information in specific situations and with specific categories of third parties. Learn more about when and with whom we share your personal information.

How do we keep your information safe? We have adequate organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.

How do you exercise your rights? The easiest way to exercise your rights is by submitting a data subject access request, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

What information do we collect?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

names
phone numbers
email addresses
mailing addresses
job titles
usernames
passwords
contact preferences
contact or authentication data
billing addresses
debit/credit card numbers
billing and invoice details
utility agreements and receipts
other payment details voluntarily uploaded by the customer

Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:

financial data
credit worthiness data

Payment Data. We may collect data necessary to process your payment if you choose to make purchases, such as your payment instrument number, and the security code associated with your payment instrument. All payment data is handled and stored by [payment processor]. You may find their privacy notice link(s) here: [payment processor privacy notice URL].

Social Media Login Data. We may provide you with the option to register with us using your existing social media account details, like your Facebook, X, or other social media account. If you choose to register in this way, we will collect certain profile information about you from the social media provider, as described in the section called “How do we handle your social logins?” below.

Application Data. If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:

Geolocation Information. We may request access or permission to track location-based information from your mobile device, either continuously or while you are using our mobile application(s), to provide certain location-based services. If you wish to change our access or permissions, you may do so in your device’s settings.
Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device’s camera, contacts, sms messages, storage, and other features. If you wish to change our access or permissions, you may do so in your device’s settings.
Mobile Device Data. We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our application(s), we may also collect information about the phone network associated with your mobile device, your mobile device’s operating system or platform, the type of mobile device you use, your mobile device’s unique device ID, and information about the features of our application(s) you accessed.
Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out from receiving these types of communications, you may turn them off in your device’s settings.

This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes:

Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called “crash dumps”), and hardware settings).
Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
Location Data. We collect location data such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. We may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.

Information collected from other sources

In Short: We may collect limited data from public databases, marketing partners, and other outside sources.

In order to enhance our ability to provide relevant marketing, offers, and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, social media platforms, and from other third parties. This information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user behaviour data), Internet Protocol (IP) addresses, social media profiles, social media URLs, and custom profiles, for purposes of targeted advertising and event promotion.

How do we process your information?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

to assess whether you may be overpaying for a service, and to estimate your potential savings;
to group your household into a regional cohort and run reverse-bid auctions with Providers on that cohort’s behalf;
to present offers to you and, if you accept one, to help complete your switch;
to facilitate account creation and authentication, and otherwise to manage your account;
to respond to your inquiries, provide support, and send you administrative information;
to maintain the security and operation of the Services, prevent fraud, identify usage trends, and improve our Services; and
with your consent, to send you marketing and promotional communications about Whollar and relevant offers.

We may also process your information to comply with our legal obligations, to enforce our terms, or to save or protect an individual’s vital interest.

What legal bases do we rely on to process your personal information?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason to do so under applicable law.

By using the Services and providing your information, you consent to the collection, use, and disclosure of your personal information as described in this Privacy Notice. Where required, we will ask for your express consent — for example, before sending you marketing messages. You can withdraw your consent at any time, subject to legal or contractual limits, though some withdrawals may mean we can no longer provide part of the Services.

We also process personal information where it is necessary to perform a contract with you, where we have a legitimate interest in doing so that is not overridden by your rights (such as securing the Services, preventing fraud, and improving our products), and where processing is required or permitted by law.

Marketing and your CASL consent

We will only send you commercial electronic messages (such as promotional emails) if you have given consent, and every message includes an easy way to unsubscribe. You can withdraw consent at any time. We will still send you messages needed to run a service you have asked for — such as auction results or account notices.

When and with whom do we share your personal information?

In Short: We may share information in specific situations described in this section and/or with the following categories of third parties.

We do not sell your personal information. We share it only as follows:

Service providers: We use trusted providers — including Zoho (Zoho Catalyst for our backend and Zoho CRM as our system of record) — to host and process information on our behalf, under contracts that require them to protect it and use it only for us.
Providers in an auction: To let Providers bid for a cohort, we share cohort information in aggregated or de-identified form wherever possible. We share the personal details a Provider needs to onboard you only after you choose that Provider’s offer.
Legal & safety: We may disclose information where required by law, to enforce our terms, or to protect people’s safety.
Business transfers: If Whollar is involved in a merger, financing, or sale, information may be transferred as part of that, subject to this Privacy Notice.

Where your information is processed

Your information is processed and stored using our service providers’ infrastructure. Where information is stored or processed outside your province, state, or country, it may be subject to the laws of that jurisdiction, and we take steps to ensure it is protected to a comparable standard.

Before publishing: confirm and state the specific Zoho data-residency region here (for example, a Canadian data centre). Naming where data is stored — and flagging any transfer outside Quebec/Canada — is a required disclosure under Law 25.

What is our stance on third-party websites?

In Short: We are not responsible for the safety of any information that you share with third parties that we may link to or who advertise on our Services, but are not affiliated with, our Services.

The Services may link to third-party websites, online services, or mobile applications, including Providers’. We cannot guarantee the safety and privacy of the data you provide to any third parties. Any data collected by third parties is not covered by this Privacy Notice. We are not responsible for the content or privacy and security practices and policies of any third parties. You should review their policies and contact them directly with any questions before sharing information with them.

Do we use cookies and other tracking technologies?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We use cookies and similar technologies to run the Services, remember your preferences, keep the Services secure, and understand how the Services are used so we can improve them. Most browsers let you refuse or delete cookies; if you do, some parts of the Services may not work as well. We use analytics data in aggregate to see which pages are useful.

Do we offer artificial intelligence-based products?

In Short: We offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies.

When you upload a bill, we use automated extraction (including machine-learning tools) to read it and pull out details such as your current provider, plan name, speed, monthly cost, contract or promotional end dates, and the service address on the bill — so you do not have to type them in. This speeds things up and reduces error.

We do not make decisions that have a legal or similarly significant effect on you by automated means alone — you decide whether to accept any offer and whether to switch. You can ask us about this processing, or ask for a person to review it, using the contact details below.

How do we handle your social logins?

In Short: If you choose to register or log in to our Services using a social media account, we may have access to certain information about you.

Our Services offer you the ability to register and log in using your third-party social media account details (like your Facebook or X logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, and profile picture, as well as other information you choose to make public on such a social media platform.

We will use the information we receive only for the purposes that are described in this Privacy Notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.

How long do we keep your information?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.

We keep personal information only as long as we need it for the purposes set out in this Privacy Notice, or as the law requires, and then we securely delete or anonymize it. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), we will securely store your personal information and isolate it from any further processing until deletion is possible. You can ask us to delete your information sooner — see What are your privacy rights?

How do we keep your information safe?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We use appropriate physical, technical, and organizational safeguards to protect your information against loss, theft, and unauthorized access, use, or disclosure. Bills you upload are transmitted over a secure connection, and access is limited to what is needed to run the Services.

However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. We work to keep your information safe — and to notify you and the relevant authorities if a breach creates a risk of serious harm, as the law requires. You should only access the Services within a secure environment.

Do we collect information from minors?

In Short: We do not knowingly collect data from or market to children under 18 years of age or the applicable age of majority.

The Services are not directed to, or intended for, anyone under the age of 18, or under the age of majority in their province, territory, or state, and we do not knowingly collect their information or market to them. By using the Services, you represent that you are at least 18 years old, or that you are the parent or guardian of such a minor and consent to that minor’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at info@whollar.com.

What are your privacy rights?

In Short: Depending on where you live, you may have rights that allow you greater access to and control over your personal information.

Depending on where you live, and under laws including Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA) and Quebec’s Law 25, you can:

access the personal information we hold about you, and ask how it has been used and shared;
ask us to correct information that is inaccurate or incomplete;
withdraw your consent;
ask us to delete your information or stop processing it; and
receive certain information you provided in a structured, commonly used technological format (data portability).

The easiest way to exercise these rights is by submitting a data subject access request, or by contacting us at info@whollar.com. We will consider and act upon any request in accordance with applicable data protection laws, and respond within the timeframes the law requires.

Withdrawing your consent. If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note this will not affect the lawfulness of the processing before its withdrawal, nor will it affect processing carried out on other lawful grounds.

Opting out of marketing communications. You can unsubscribe from our marketing and promotional communications at any time by clicking the unsubscribe link in the emails we send, or by contacting us. You will then be removed from the marketing lists — however, we may still communicate with you to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

If you are located in Canada and are not satisfied with our response, you can contact the Office of the Privacy Commissioner of Canada, or, in Quebec, the Commission d’accès à l’information du Québec.

Controls for Do-Not-Track features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

Do United States residents have specific privacy rights?

In Short: If you are a resident of a US state with a comprehensive privacy law, you may have the right to request access to and receive details about the personal information we maintain about you, correct inaccuracies, get a copy of it, or delete it.

We do not sell your personal information. Depending on the state you live in, you may have some or all of the following rights:

the right to know whether we are processing your personal information, and to request access to it;
the right to request that we correct inaccuracies in your personal information;
the right to request a copy of your personal information in a portable format;
the right to request deletion of your personal information;
the right to opt out of the sale of personal information, of targeted advertising, and of certain profiling;
the right to limit our use and disclosure of sensitive personal information; and
the right not to be discriminated against for exercising any of these rights.

To exercise any of these rights, submit a data subject access request or contact us at info@whollar.com. We may need to verify your identity before responding, and we will respond within the period required by your state’s law. If we decline to act on your request, you may appeal that decision by contacting us at the same address.

Do we make updates to this notice?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. We will post the updated version here and change the “Last updated” date at the top. Significant changes will be communicated where appropriate, either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

How can you contact us about this notice?

If you have questions or comments about this notice, you may contact us at:

Whollar Inc.
info@whollar.com
[Mailing address]

How can you review, update, or delete the data we collect from you?

Based on the applicable laws of your country or state, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law.

To request to review, update, or delete your personal information, please submit a data subject access request or contact us at info@whollar.com.