Raange™ Privacy Policy
Effective date: January 7th, 2024
Your privacy is important to Raange Inc. and its affiliates, which includes Raange Interactive, Inc. (collectively, “Raange”, “we”, “us”, or “our”). Raange provides this Privacy Policy (the “Policy”) in order to describe how we collect, use, disclose, retain, destroy, or otherwise process (collectively, “process”) your personal information, as defined in the Definition of “personal information” section below. Specifically, the purpose of this Policy is to explain how and for what purpose Raange processes your personal information in the context of offering our services such as end-user SMS communication and two factor authentication (“collectively, the “services”), including information we may collect when you sign up for the use of our services, visit Raange’s website www.Raange.com, access your online Raange account, or when you reach out directly to Raange representatives for customer care matters (“Customer personal information”). This Policy also governs our indirect processing of the personal information of your end users in the context of offering you our services (“End-User personal information”).
Please take the time to familiarize yourself with this Policy, as it also describes your privacy choices and how you can contact us if you have questions or would like to exercise your rights under applicable privacy laws. This Policy applies to Customers accessing our website in Canada and/or receiving services while located in Canada and to End-Users receiving our SMS while located in Canada.
Table of content
1. Definition of “personal information”
2. How Raange Collects Personal Information
3. How Raange Uses Personal Information
4. How Raange Shares Personal Information
6. Retention of Personal Information
7. Protection of Personal Information
8. Consent and Your Right to Withdraw Consent
1. Definition of “personal information”
In this Privacy Policy, “personal information” generally means any information that can be used, either alone or in combination with other information, to identify an individual. This includes information such as your name, mailing address, email address, telephone number, or any other contact details. It may also include other types of more technical information, but only when this information can identify you as an individual. Information that is anonymized and cannot be associated with an identifiable individual is not considered to be personal information, if it is, at all times, reasonably foreseeable in the circumstances that this information irreversibly no longer allows the individual to be identified directly or indirectly.
Please note that to the extent permitted by applicable law, the provisions of this Privacy Policy concerning personal information do not apply to information that enables you to be contacted at a place of business, such as your name, position or title, business address, business telephone number, and business email address.
2. How Raange Collects Personal Information
Raange collects Customer personal information directly from you when you visit Raange’s website, request our services, or when you contact a member of the Raange team or sign up for a Raange account to use our services. Raange also collects End-User personal information in the context of providing you with its services. Specifically, Raange collects the following types of personal information from Customers and End-Users:
Information collected directly from Customers
- Contact information. You may be asked to provide your contact information (e.g., email, name, address, etc.) to Raange when you create a Raange account or request Raange’s communication services (through Raange’s website) or when you are otherwise in contact with Raange. In these circumstances, you can choose not to provide certain requested personal information, but then you might not be able to create an account or obtain certain features of Raange’s services.
- Financial information. You may be asked to provide your financial information (e.g., bank account number) when you request Raange’s services for the purpose of allowing Raange to process your payment for said services.
Information collected directly from End-Users
- Contact information. In order to receive SMS messages from our Customers, you may be asked to provide Raange with your contact information (e.g., your name, telephone number, and email address). For information on how you may unsubscribe from such commercial electronic messages (“CEMs”) at any time, please consult the Consent and Your Right to Withdraw Consent section below.
- Information about your friends and family. You may also be presented with the option to provide Raange with the contact information of other individuals, such as your family or friends. Please ensure that you have the consent of those individuals before you provide their personal information to Raange.
Information collected from Customers about End-Users
- Contact information. In order for you to receive SMS messages from our Customers, you may be asked to provide Customers with your contact information (e.g., your name and email address). Our Customers will then share your contact information with us if you subscribed to their SMS or may otherwise receive SMS from them in compliance with applicable law. For information on how you may unsubscribe from such CEMs at any time, please consult the Consent and Your Right to Withdraw Consent section below.
Information collected automatically
Raange may automatically collect certain information regarding your use of our services, or website, such as the dates and times you access Raange’s website and the browsers, operating systems, devices you use to access them and your Internet Protocol (IP) address. Raange may use that information for various purposes, including to administer and improve Raange’s website. This information may also allow Raange to recognize you as a user of Raange’s website or services, monitor your use of Raange’s website or services, offer you personalized online content, information and advertisements, and otherwise facilitate and improve your use of Raange services.
To automatically collect your information, Raange may use “cookies” and other similar technologies, such as pixel or gif tags, and action tags. You may choose to decline or disable cookies if your web browser permits, but doing so may affect your ability to access or use certain features of Raange’s website and services. See the Consent and Your Right to Withdraw Consent section for more information about how you may withdraw your consent to Raange’s use of cookies.
3. How Raange Uses Personal Information
Raange may use your personal information for general business purposes such as providing or delivering the Program, managing our business and website, preventing or reducing commercial risk, as well as for purposes relating to our information system or network security.
More specifically, Raange may use your personal information for the following purposes:
- Providing or delivering our products and services, including our SMS marketing services. We may use Customer personal information to set up and manage your Raange account and deliver our services, including to facilitate your transactions with Raange. We may use End-User personal information to send End-Users SMS in the context of offering Customers our services, including SMS marketing services.
- Managing our website and app. We may use your personal information to manage and facilitate the use of our website or app when you visit or access them, which may include using cookies and other similar technologies (see the Consent and Your Right to Withdraw Consent section for more information on how you may withdraw your consent to Raange’s use of cookies).
- Marketing and customer relation purposes. We may use your personal information to understand your needs and preferences, provide you with personalized content and services, such as tailoring our customer experience and offerings, and deciding which offers or promotions to show you.
- Communicating with you. If you contact us with a question, inquiry, or feedback about Raange’s services, we may use your personal information to respond to you. We may also communicate with you for business development purposes, to promote our services and offers, to facilitate your participation in promotions and contests, and to notify you about changes to our services.
- Business intelligence and analytics. We may use your personal information to develop, deliver, and improve Raange’s services and advertising. Raange may achieve this purpose by combining your personal information collected through various sources, including information collected through Raange’s website to offer you improved services.
- For other purposes permitted or required by law. We may use personal information without your consent where we are legally permitted or required to do so by law, for example, to comply with a legal obligation or to protect the rights, including property rights, intellectual property rights such as copyright, and interests of Raange, to protect the security of Raange’s employees, Customers, and End-Users, or in order to enforce or apply our Terms of Use and other agreements, or to detect, prevent and investigate suspicious, unauthorized, fraudulent, illegal or unlawful activity.
4. How Raange Shares Personal Information
To manage and deliver our services, we share information with our affiliates, third-party service providers, and certain other third-parties in order to conduct our business activities and to protect our rights. For example, we share information with the following entities:
- Affiliates. Raange may share your personal information with its affiliates, which will, in turn, process your personal information in accordance with this Policy.
- End-User information shared with Customers. If you register to receive SMS from a Customer, or you otherwise expressly consent to Raange sharing your personal information with a Customer, then Raange may share your personal information (including your contact information and whether you have consented to receiving commercial electronic messages from Raange and/or the Customer) to said Customer. Raange has no control over, or responsibility or liability for, the processing of your personal information by the Customer. The Custome’s processing of your personal information is governed by the Customer’s own privacy policy (i.e.m not by this Policy). We recommend that you consult the Customer’s website to consult their privacy policy.
- Service providers. Raange may share your personal information with Raange’s suppliers and service providers to assist Raange in the provision of its services, including for Raange to receive marketing, data analytics, data protection and stores services. Raange requires its suppliers and service providers to agree to use your personal information only for the purposes for which the information is provided to them, and to protect the privacy of your personal information in a manner that is consistent with this Policy.
- Law enforcement and other legally required disclosures. Raange may share your personal information as required or authorized by applicable law, including to comply with a subpoena, warrant or court or arbitral order, or litigation disclosure obligations. As such, your personal information may be subject to access by and disclosure to law enforcement agencies in accordance with applicable law. Moreover, Raange may share your personal information if Raange reasonably believes that doing so is necessary or appropriate in connection with national security, law enforcement or other issues of public importance, as well as with the protection and enforcement of Raange’s legal rights, interests and remedies or to protect the business, operations or customers of Raange or other persons, including to detect or prevent unlawful or fraudulent activities or other misconduct in connection with a test session or test results.
- Business transactions. Raange may share your personal information in connection with a proposed or actual business transaction in which Raange is involved (such as a corporate reorganization, merger or acquisition, or the sale of some or all of Raange’s business or assets) in compliance with applicable law. In such a scenario, Raange will require that the information recipient agree to protect the privacy of your personal information in a manner that is consistent with this Policy and applicable law.
5. Cross-border Transfers
Raange may process, store and use your personal information at facilities in various regions and countries outside of Quebec and outside of Canada, including in the United States. The personal information protection laws of those other countries might be different from the laws of jurisdiction in which you reside, and might permit courts, government, law enforcement agencies, regulatory agencies and security authorities to access your personal information. By providing Raange with your personal information, you consent to the transfer of your personal information to facilities located in other countries and the processing and storage of your personal information at those facilities.
6. Retention of Personal Information
Raange retains your personal information for the period reasonably necessary for the purposes set forth or referenced in this Policy or a longer retention period required or permitted by applicable law. Raange will delete, dispose, or make anonymous your personal information when Raange is no longer reasonably required to retain the information for the purposes set forth or referenced in this Policy.
7. Protection of Personal Information
Raange employs reasonable safeguards – including administrative, physical and technical security and safeguarding measures and solutions – appropriate to the sensitivity of the personal information in Raange’s possession or under Raange’s control in order to protect the information from unauthorized access, collection, use, disclosure, disposal or similar risks, We specifically implement a combination of measures to protect your personal information, including:
- Internal policies and procedures that define the roles and responsibilities of our employees throughout the life cycle of an item of information and limit their access to that information on a “need-to-know” basis;
- Physical, electronic and procedural safeguards that comply with relevant standards to protect personal information;
- If the information is collected or stored electronically, technical safeguards such as encryption, firewalls, passwords, anti-virus software and similar measures;
- A designated Chief Privacy Officer to monitor Raange’s compliance with applicable privacy laws;
- Employee training in privacy and information security; and
- Procedures for receiving, investigating, and responding to complaints or inquiries about Raange’s information handling practices.
Note that although we take the measures above to protect your personal information, security risks cannot be eliminated and Raange cannot guarantee that your personal information will not be used or disclosed in ways not otherwise described in this Policy.
8. Consent and Your Right to Withdraw Consent
By providing Raange with your personal information, you consent to the processing of that information in accordance with this Policy and as otherwise permitted by applicable law.
If you are under the age of majority in the jurisdiction in which you reside (which in most jurisdictions is either 18 or 19 years of age), then your parent or legal guardian must register for Raange’s SMS services on your behalf, and by doing so, your parent or guardian consents, and confirms that you consent, to the processing of your personal information in accordance with this Policy for the purpose of you obtaining our services and as otherwise permitted by applicable law.
Withdrawing your consent to data processing practices
Please be advised that you have a right to withdraw your consent to Raange’s processing of your personal information to the extent permitted by law and Raange’s contractual obligations. If you desire to do so, please contact Raange using the information provided in the Contact Us section. Depending on the circumstances, your withdrawal of consent to the processing of your personal information may prevent us from providing you, or continuing to provide you, with some products and services, the ability to access certain products and services. We will act on your instructions as quickly as possible but there may be certain uses of your information that we may not be able to stop immediately or that may have to continue after your consent withdrawal, as required by applicable law.
Withdrawing your consent to receiving CEMs
Note that, if you are an End-User that receives CEMs, including SMS from Raange on behalf of one of its Customers, you may specifically withdraw your consent to the use of your personal information in connection with us providing you with such marketing SMS.
You can withdraw your consent to receiving marketing SMS from Raange by responding to any SMS with “STOP”. Unsubscribe requests and changes to communication preferences will be completed within 10 days from date of request.
Withdrawing your consent from the use of cookies
You can disable cookies using your Internet browser’s settings. Please consult your browser’s help function for information on how to disable cookies. Note that if you disable cookies, certain features of our website may not function properly. You may also edit your preferences when it comes to Raange’s use of cookies by changing them through our Cookie Preferences Center on our corporate site www.raange.com.
9. Your Rights
Depending on the region in which you reside, you may be entitled to access your personal information and request the correction of inaccurate information, subject to limited exceptions set out in applicable laws.
Correction of Customer Personal Information. Raange relies on its Customers to ensure that their personal information is as accurate, complete and up to date as necessary for the purposes of the services that Raange provides to them. Customers must promptly notify Raange of any changes to their personal information, including to their Raange account information, by using the procedures provided on Raange’s website or by contacting Raange’s Customer Care at customercare@raange.com.
Correction of End-User Personal Information. End-Users may request that their personal information be corrected by submitting a written request to Raange’s Chief Privacy Officer using the information provided in the Contact Us section below.
Access to Personal Information. You may request access to your personal information by submitting a written request to Raange’s Chief Privacy Officer using the information provided in the Contact Us section below. Subject to applicable exceptions and limitations prescribed by applicable law, you will be given reasonable access to your personal information. You may be required to pay a reasonable fee for access to your personal information.
Information on Raange’s Processing of Your Information. You may request, to the extend permitted under applicable law, information about Raange’s processing of your personal information by submitting a written request to Raange’s Chief Privacy Officer using the information provided in the Contact Us section below.
Note that if you are an End-User submitting a request to exercise any of the rights described above to Raange, Raange may, in order to respond to your request, collaborate with the relevant Customer on whose behalf it has been sending you marketing SMS.
10. Minors
Notwithstanding the information provided in the Consent and Your Right to Withdraw Consent section, Raange does not knowingly collect personal information from or relating to children who are under 14 years of age without the consent of the child’s parent or legal guardian. Raange expects parents to supervise and monitor their children’s disclosure of personal information. Please immediately contact Raange using the information provided in the Contact Us section below if you believe that Raange has unintentionally collected personal information from a child under 14 years of age without the consent of the child’s parent or legal guardian. If Raange learns that it has inadvertently collected the personal information of a child under 14 years of age without appropriate consent, Raange will use reasonable efforts to delete that information from Raange’s systems (except to the extent that retention of the personal information is required or permitted by applicable law).
11. Third-Party Websites
Raange’s website may contain links to other websites or online services not controlled covered by this Policy. Raange has no responsibility or liability for, or control over, those other websites or service or their processing of your personal information. When providing personal information on such other websites, we encourage you to read the privacy policies and terms of use of those sites.
12. Changes to this Policy
This Policy is current as of the Effective Data set forth above. Raange may change this Privacy Policy from time to time and publish a new version of this Privacy Policy on Raange’s website. Raange’s processing of your personal information will be governed by the version of this Privacy Policy in effect at that time. Your continued dealings with Raange subsequent to any change to this Privacy Policy will signify your consent to the processing of your personal information in accordance with the changed Privacy Policy. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our websites or by contacting you if required by applicable law.
13. Contact Us
If you have any comments or questions about this Privacy Policy or about how Raange processes your personal information, please contact Raange’s Chief Privacy Officer by mail or email at:
Raange – Chief Privacy Officer
6500 TransCanadian Highway, Suite 400,
Pointe-Claire, Quebec, Canada
H9R 0A5
Email: privacy@Raange.com