FHTII is committed to and has a long-standing policy of maintaining the privacy and security of your personal information. Personal information is information about an identifiable individual (as defined by applicable privacy or data protection laws).
FHTII is responsible for personal information under its control, including the onward transfer of personal information to a third party for processing on FHTII’s behalf.
2. Purposes for Using Your Personal Information
When you use a FHTII Offering, correspond with BlackBerry, enter a contest sponsored by FHTII or otherwise interact with FHTII, FHTII may process your personal information for the following purposes:
to understand and meet your needs and preferences, and to provide you with FHTII Offerings, e.g.:
for purposes related to the billing, activation, provision, maintenance, support, trouble shooting, resolving of disputes, deactivation, repair, refurbishment, replacement, upgrade or update of FHTII Offerings;
to ensure FHTII Offerings are technically functioning as intended and to help identify and troubleshoot issues;
to understand your use of the network or FHTII Offerings by interpreting network performance and use metrics;
to fulfill or enforce Notices applicable to a FHTII Offering;
to manage or respond to your inquiries;
to develop new and enhance existing FHTII Offerings including to communicate with you about them using various means, e.g. to make available or send to you:
upgrades or updates, or notices of upgrades or updates of FHTII Offerings or third party content or related products, services and software;
notices of promotions and upcoming events;
to manage and develop our business and operations, e.g.:
to detect, monitor, investigate, mitigate or attempt to prevent fraud and technical or security issues or to protect FHTII property;
to allow for business continuity and disaster recovery operations;
to enforce FHTII’s legal rights;
for statistical purposes;
to meet legal and regulatory requirements and to respond to emergency situations, e.g.:
to respond to court orders, warrants or other lawful requests or legal processes;
to provide emergency assistance in situations that may threaten the life or physical safety of you or others;
or for any other purposes for which you have consented, such as those that may be set out in Notices, and other purposes as permitted or required by any applicable law.
Before using FHTII Offerings, you may be required to agree to an applicable Notice that may contain additional information regarding FHTII’s processing of your personal information. Your agreement to the Notice or use of FHTII Offerings indicates your consent for FHTII to process your personal information for FHTII’s identified purposes.
If you provide FHTII with personal information about another person, you are responsible for ensuring you have that individual’s consent to do so. All personal information provided to FHTII is subject to this policy.
a) When Obtaining Consent is Not Required
In certain circumstances, your personal information may be processed without your consent depending on the jurisdiction and any applicable laws. For example, FHTII may not seek consent:
in the case of an emergency where the life, health or security of an individual may be threatened;
when legal, medical, or security reasons make it impossible or impractical to seek consent;
when personal information is necessary to detect, monitor, investigate, mitigate or attempt to prevent fraud and technical or security
issues or to protect FHTII property;
when disclosure is to a lawyer representing FHTII;
to collect a debt;
to comply with a subpoena, warrant or other court order, lawful request or legal process; or
as may be otherwise required or permitted by law.
FHTII does not knowingly process personal information from individuals under the age of 13 without the consent of their parent or legal guardian.
c) Aggregated or Anonymous Information
FHTII reserves the right to process, sell, trade or rent aggregated or anonymous information that is not associated with or linked to an identifiable individual.
4. Types of Personal Information Processed
The types of personal information that FHTII may process can vary. For example:
a) Account and membership information: Personal information processed could include your name, postal address, email address, telephone number, airtime service provider information, communications with FHTII and any recorded complaints. FHTII may also process your account credentials, passwords, profile information and other personal information you provide to facilitate the FHTII Offerings you use.
b) Applications: In some cases, FHTII may process personal information about applications used on your device including Third Party Offerings (i.e. applications, products, services, software, websites or content provided by a third party, including an airtime service provider or application developer, that may be used in conjunction with FHTII Offerings, but are not offered, operated or supported by FHTII). Also, if you choose to use Third Party Offerings with your FHTII account, certain personal information may be collected and disclosed to the third party, or from the third party to FHTII, in order to facilitate or improve the services and functionality provided.
c) Cloud-based or back-up data: If you use a cloud-based or back-up and restore service provided by or on behalf of FHTII, personal information including contacts, email addresses, calendar, memo, tasks, display pictures, status messages, media files and other on-device information may be sent to FHTII in order to facilitate or improve the use, remote access and restoration of that data on your device through the service provided.
d) Cookies or similar technologies: A cookie is a small text file or piece of data that is downloaded to and stored on your computer or device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognizes the cookie. As part of FHTII’s Offerings, FHTII may use different types of cookies or similar technologies (“Cookies”) from time to time. Certain Cookies are necessary to facilitate your use of FHTII Offerings (such as when you use a shopping basket) or to protect both you and FHTII when you sign-in to certain services (such as storing your credentials to make it easier whenever you want to use FHTII Offerings or to confirm that you are logged in). Other Cookies are more performance-related such as for analytics or contextual purposes to help us understand how users engage with FHTII Offerings so we can provide new and enhanced FHTII Offerings (such as which pages or features are most popular). Some Cookies are more function-related and help personalize your experience and make FHTII Offerings easier to use (such as your language or jurisdiction preferences), or to help FHTII display personalized content to you.
e) Financial information: If you purchase a product, service, software or customer support directly from FHTII or our service providers, FHTII may process credit card or other payment information and use it to facilitate billing and credit services and conduct credit checks, as applicable. Similarly, FHTII may process payment or other financial information when you use Near Field Communications functionality.
f) General usage data: In some cases, personal information that includes technical properties and general usage information of software and hardware utilized in conjunction with a FHTII Offering might be processed when you use such products, services or software (e.g. type of web browser, referring or exit web pages, operating system version, hardware model of your device or personal computer platform, IP address), or when you use a FHTII troubleshooting tool (e.g. basic usage statistics or information about your device including event logs, application configurations, battery life, radio or Wi-Fi signal levels, device reset and memory or system performance information).
h) Quality assurance and customer service: Your customer service telephone calls with FHTII and FHTII’s service providers may be recorded or monitored for quality assurance and customer service purposes such as to assist in addressing your inquiries, troubleshooting, training and analytics to identify trends and make improvements to FHTII Offerings.
j) Gmail user data use limitations: When you allow FHTII Offerings to access your Gmail account, BlackBerry Offerings will only access and use Gmail user data, which includes messages, attachments, contacts, metadata, and settings, to provide you the ability to compose, send, read, and process email messages and manage your contacts. FHTII Offerings will not transfer Gmail user data to Third Parties unless necessary to provide or improve the features of the FHTII Offering, comply with applicable law, or as part of a merger, acquisition, or sale of assets. FHTII Offerings will not use Gmail user data for serving ads, or interest-based advertising. FHTII personnel will only access aggregated and anonymized data and will not access Gmail user data unless you have provided your affirmative consent for specific messages, or unless doing so is necessary for security purposes such as investigating abuse, to comply with applicable law.
5. Processing Your Personal Information
FHTII retains personal information as long as necessary for the fulfillment of FHTII’s identified purposes or as otherwise necessary to comply with applicable laws. When personal information is no longer necessary or relevant for FHTII’s identified purposes, or required by applicable laws, FHTII will take steps to have it deleted, destroyed, erased, aggregated or made anonymous. Consistent with good business practice, FHTII continues to evolve our controls, schedules and practices for information and records retention and destruction which apply to your personal information.
b) International operations and onward transfers
You agree that, to be able to better serve you and facilitate the use or functioning of FHTII Offerings, your personal information may be collected, used, processed, transferred or stored by or on behalf of FHTII in multiple jurisdictions including Canada, the United States, the European Economic Area, and any other country where FHTII or our service providers have offices or facilities, including countries which may be outside the region in which you are situated and may have different privacy or data protection legislation, and may therefore be subject to the laws of these countries. If you are a resident of the European Economic Area or a country which restricts data transfers outside of that jurisdiction or region without your consent, you consent to your personal information being transferred outside of the European Economic Area or your country for processing or storage by or on behalf of FHTII.
Given the international nature of our business, FHTII may also be required to disclose or otherwise provide access to your communications data, including the contents of your communications, and other personal information under the laws of countries where FHTII, our service providers, affiliates and data are located. By using FHTII Offerings, you consent to our compliance with applicable laws including any legal process that FHTII believes requires that we produce or provide access to your communications data and other personal information.
c) Marketing communications from FHTII
FHTII may communicate information, surveys, marketing materials, advertisements or customized content which has been personalized to try to make it more relevant to you as part of your existing business relationship with FHTII. For example, we may do so where you have not unsubscribed from receiving such communications and it is permitted by law, where you have explicitly agreed to receive such communications, where you use free services which rely upon advertising (including targeted advertising based on profile information), or through utilizing aggregated data or data that has been made anonymous. FHTII may ask you from time to time if you would like to receive from FHTII or authorized third parties selected by FHTII additional announcements, news, offers or event invitations regarding FHTII and FHTII Offerings. You may also choose to provide FHTII with personal information in response to various FHTII promotions. If you agree to participate in contests, surveys, giveaways, reviews, or other promotions that FHTII sponsors or co-sponsors, please ensure that you read the Notice that may be associated with these initiatives in order to obtain further details about how your personal information will be managed. An unsubscribe mechanism is included with every FHTII marketing or commercial communication. Please visit the section below on “Withdrawing Your Consent” for more information on managing marketing or commercial communications from FHTII.
d) Service-related communications from FHTII
FHTII may also send you certain service-related communications. For example, FHTII may send a welcome email or message when you first activate a FHTII Offering to inform you about the service and its terms, to notify you of important changes, to tell you how to manage your credentials or account, to provide service infrastructure notifications or information about upgrades or updates, to provide warranty information, product recall information, safety or security information, or for surveys of current or former users. Because such service-related communications are important to your use of BlackBerry Offerings, you may not opt-out of receiving these communications.
e) Information sharing
FHTII uses contractual or other means to provide a comparable level of protection while the personal information is being processed by our service providers. It is FHTII’s policy to enter into confidentiality obligations with any third party that obtains confidential information including personal information from FHTII. For example, except where FHTII is required or permitted by law to disclose personal information, our service providers to whom we provide your personal information typically agree to hold the personal information in confidence and only use the it for the purposes for which it was provided or to comply with applicable laws.
In the event of the sale of all or a portion of FHTII’s assets, FHTII may provide personal information to the third party purchaser.
FHTII may utilize third parties (e.g. advertising networks) to target advertisements at non-personally identifiable attributes or aggregated data that is derived from profile data processed by FHTII, and provide such third parties with general statistics relating to the advertisements delivered. Please visit the section below on “Withdrawing Your Consent” for more information on managing marketing or commercial communications from FHTII.
f) Third Party Offerings
FHTII does not own or operate all the applications or services that you download and use on your device or through other FHTII Offerings. When you download or utilize Third Party Offerings, personal information from your device or other FHTII Offerings may be accessed by such third parties. For example, a Third Party Offering might access on-device data such as contacts, calendar entries, email, location-based information, or it may access or share files or data stored on the device (including with additional Third Party Offerings). You should review the privacy policies and any agreements with such third parties to understand how your personal information will be processed by those entities, as FHTII is not responsible for your dealings with third parties or their applications, products, services or software. FHTII does not directly control how such third parties process the personal information they collect in connection with the Third Party Offerings you use.
In some cases, you may adjust the permissions granted to Third Party Offerings. You should periodically review these permissions including default permissions, as well as the Options or Settings menu on your device, in order to learn more about its security and available controls.
6. Accuracy of Your Personal Information
FHTII takes reasonable steps to ensure that personal information is sufficiently accurate, complete and up-to-date. FHTII also depends on you to update or correct your personal information whenever necessary.
7. Safeguarding Your Personal Information
FHTII continues to evolve our physical, organizational and technological measures used to protect your personal information. For example, if a FHTII website requests your name and password, it will have a variety of security measures in place that are designed to protect against the loss, misuse and unauthorized alteration of the personal information submitted to FHTII. Through FHTII’s Code of Business Standards and Principles, FHTII employees are made aware of the importance of appropriately and securely handling personal information, to keep it in secure locations and systems, and to limit access to personal information to those with a need to know it for business reasons.
In addition, certain FHTII systems and processes are externally inspected on a regular basis.
a) Your obligations to safeguard your personal information
You have an obligation to safeguard your personal information. You can reduce risk of unauthorized access to your personal information by using common sense security practices. For example, you are responsible for utilizing appropriate security measures to control access to your device and computer system, such as creating a strong password that cannot be easily guessed by others (e.g. by including punctuation marks, numbers, capital and lowercase letters, and choosing a password of an appropriate length and which does not include your name or account name), using different passwords for different services and using up-to-date antivirus software.
As noted above, in some cases, you may adjust the permissions granted to Third Party Offerings. You should periodically review these permissions including default permissions, as well as the Options or Settings menu on your device, in order to learn more about its security and available controls.
If you return, sell, discard, or transfer your device or other FHTII product to another person or entity (such as providing your device to FHTII or another entity for repair, refurbishment or replacement), you should ensure that the device and any associated accessories and peripherals are removed or securely wiped of any personal information or other sensitive data they might contain (e.g. SIM cards, microSD cards). You should also disassociate your device from all email accounts and other data services so that email and data are no longer directed to the device (e.g. push services, emails delivered through the FHTII Internet Service, remote backup). Otherwise, your personal information may be available to a subsequent user of the device, and you may incur subscription and network data charges. You may learn more about how to take steps to protect yourself through the Options or Settings menu on your device, searching support articles online at www.fhtii.com, or by contacting your airtime service provider.
8. FHTII’s Ongoing Efforts to Be Transparent
9. Accessing Your Personal Information
Upon written request, FHTII will inform you whether it holds personal information about you and provide you with access to your personal information within a reasonable timeframe and at minimal or no cost in accordance with applicable laws. If you identify an inaccuracy or incompleteness in your personal information, FHTII will amend your information and notify any third parties as required by applicable laws.
In certain situations, and depending on applicable laws, FHTII may not be able to provide access to all of the personal information that it holds about you. For example, FHTII may not provide access to personal information if doing so:
would likely reveal personal information about a third party;
could reasonably be expected to threaten the life or security of another individual;
would reveal FHTII or third party confidential information;
includes information that is protected by solicitor or attorney client privilege;
or includes information that was processed in relation to the investigation of a breach of an agreement or a contravention of a law.
In order to safeguard your personal information from unauthorized access, FHTII may ask that you provide sufficient information to identify yourself prior to providing access to your personal information.
Depending on the circumstances and applicable laws, FHTII may refuse to process certain access requests (e.g. access requests that are unreasonably repetitive or systematic, would be extremely impractical or require disproportionate technical effort).
10. Questions or Concerns
a) Withdrawing Your Consent
You may withdraw your consent at any time by notifying the Privacy Office at FHTII’s Facebook.
If material changes are made that impact you, we will notify users by placing a prominent notice at www.fhtii.com. Depending on the circumstances, we may also decide to send users a notice electronically. If you continue to use your FHTII Offerings after notice of the change has been given, you will be deemed to have accepted such changes.
Last Updated June 20, 2019