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  1. Introduction

The purpose of this privacy policy is to inform Users of our On Set 20 (the “App”) of the following:

  1. The personal data that we collect;

  2. The use of the data collected;

  3. Who has access to the data collected; and

  4. Your rights as Users of the App.


This privacy policy is supplemented with the terms and conditions of the App.


On Set 20 has established and implemented internal policies and procedures designed to adequately protect the personal information in our possession and we review these policies and procedures on a regular basis. We make our employees aware of the importance of protecting personal information by requiring them to receive training on this matter and by issuing directives outlining their role and obligations in this regard from time to time.


    2. Applicable laws

This policy complies with the laws set out in the Personal Information Protection and Electronic Documents Act (PIPEDA). For residents of the State of California, this privacy policy is intended to comply with the California Consumer Privacy Act (CCPA). If there are any inconsistencies between this document and the CCPA, the CCPA shall prevail. If we find any inconsistencies, we will change our policy to comply with the relevant law (collectively, the “Laws”).


    3. Consent

Subject to the exceptions and requirements of the applicable laws, we shall not communicate or disclose your personal information to any other third party without your free, informed and express consent.


Users agree that by using the App, they consent to:

  1. The conditions set out in this privacy policy and;

  2. The collection, use and storage of the data listed in this policy.


You can withdraw your consent at any time, subject to the applicable legal restrictions.


In exceptional circumstances, we may collect, use, or disclose personal information without your knowledge or consent. Such circumstances arise when, for legal, medical or security reasons, it is impossible or unlikely to obtain your consent or when the information is necessary to apply the law.


    4. Personal data that we collect


Any factual or subjective information about an identifiable person is considered personal information. For example, personal information may include, but is not limited to, first and last name, address, phone numbers, gender, email address, information about your marital status, your lifestyle or your health.


Data collected automatically through the App 

When you visit and use the App or App, we may automatically collect and store the following information:

  1. Location;

  2. Hardware and software details;

  3. Content that the User consults on the App.



Data collected non-automatically through the App

We may also collect the following data when you use specific functionalities on the App:

  1. First and last name;

  2. Email;

  3. Union affiliation number;

  4. Union Name;



This data may be collected through a form. Please note that we only collect data that helps us achieve the purpose set out in this privacy policy. We will not collect additional data without notifying you first.


    5. How we use personal data

Personal data collected on the App will be used only for the purposes specified in this policy or to provide the services offered on the App as indicated on the relevant pages of the App. We will not use your data beyond what we disclose.


The data that we collect automatically is used for the following purposes:

  1. Provide, perform, and maintain our services;

  2. Send transactional messages, including replies to your comments, questions and requests; provide customer and support services; send technical notices, updates, security alerts, as well as support and administrative messages;

  3. Send promotional communications by email, including information on products and services, news, surveys, newsletters, offers, including specials, promotions, events and other information that may be of interest to you;

  4. Customize the App according to your interests; and

  5. Monitor and analyze trends, use and activities in connection with the App and services provided as well as for marketing or advertising purposes.


The data that we collect when the User performs certain things on the App may be used for the following purposes:

  1. To reply to your requests for information;

  2. To improve our service offering;

  3. To meet the requirements of the laws; and

  4. To control the quality of customer service and prevent errors and fraud.



We limit the collection, use and disclosure of your personal information to the purposes we have indicated to you. Your personal information may only be viewed by certain authorized persons, and only in the context of the tasks assigned to them.


In general, we do not disclose your personal information without obtaining your free, informed and express consent. In all cases, we comply with the restrictions and requirements prescribed by law. We do not sell your personal information to third parties.


    6. With whom do we share personal data


We may disclose User data to any member of our organization that reasonably need such data to achieve the purposes set out in this policy.


Third parties

We may share User data with the third parties which provides the infrastructure to enable the services provided by the App, such as, but not limited to, the data center provider and the tools used to maintain the App. Notwithstanding the above, in no event do those third parties have the authorization to use your personal data for any other purpose than providing the services contemplated by the App. Third parties will not be able to access User data beyond what is reasonably necessary to achieve the expected purposes.


    7. Other disclosures

We undertake not to sell or share your data with third parties, except in the following cases:

  1. If required by law;

  2. If required for any legal proceedings; and

  3. To enforce or protect our legal rights.


​    8. How long do we store personal data

We do not store User data beyond what is necessary to fulfill the purposes for which it is collected. We will destroy such data in accordance with the law and our record retention policy. When we destroy your personal information, we take the necessary steps to maintain its confidentiality and ensure that no unauthorized person may gain access to it during the destruction process.


    9. How we protect your personal data

We are committed to protecting your personal data. In order to prevent unauthorized access or disclosure of any personal data, we have implemented technical and organizational measures to protect and ensure its security. To ensure the security of personal data, we have built the App and App using encryption and authentication tools that meet industry standards. While we take all reasonable precautions to ensure that User data is secure and Users are protected, there is always risk. The cyberspace as a whole may be insecure at times and therefore, we are unable to guarantee the security of User data beyond what is reasonable.


    10. International data transfers

User data can be viewed, processed or collected in the following countries:

  1. United States; and

  2. Canada.


    11. Your rights as User

As User, you have the right to access all personal information that we have collected. In addition, you have the right to update or correct any personal data in our possession, in accordance with the applicable law.


You may choose to withdraw or change your consent to the collection and use of data at any time, provided it is legally acceptable to do so and that you provide us with reasonable notice.


You may, following the filing of a request with reasonable notice, and subject to any regulatory restrictions, consult or request the correction of personal information that we have about you.


We will provide you with such information within a reasonable time from the date of receipt of the written request. However, fees may apply to process your request.


In special circumstances, we may refuse to provide you with the information requested (e.g., if such information cannot be disclosed for legal or security reasons). These limitations are described in the Act respecting the protection of personal information in the private sector.


You can verify the accuracy and exhaustiveness of your personal information and, if necessary, request that it be amended. Any request for modification will be dealt with in accordance with the applicable laws.


​    12. How to modify, delete or contest the data collected

If you would like your information to be removed or modified in any way, please contact our privacy officer at


​    13. Accuracy

We do everything in our power to ensure that your personal information is accurate and complete for the purposes for which it was collected, used or disclosed. However, On Set 20 does not have the mandate to verify the accuracy of User data. On Set 20 simply acts as a technology platform for collecting and presenting data. 


    14. ​Responsibility

We are responsible for the personal information in our possession, including information we entrust to third parties for the purpose of providing you the requested service. We require that these third parties store such information according to strict confidentiality and security standards. Notwithstanding the above, in no event is On Set 20 responsible for any personal information that you shared, intentionally or not, but which was not expressly collected by us. For example, if personal information is contained on a picture of a food receipt you upload on the App for tracking purposes, please be reminded that On Set 20 doesn’t ask for, or do anything with the information you provided. In any event, no such information is targeted by any data collection software and On Set 20 does not have any intention to collect, share or use such data.


We comply with the principles set out by law. We have policies and guidelines in place to protect your privacy. Our personal information protection and information technology security officers oversee this personal information protection policy as well as the various corporate frameworks.


Our staff are knowledgeable and adequately trained on privacy policies and practices.


    15. Modifications

This privacy policy may be amended from time to time in order to comply with the law and to reflect any changes to our data collection process. We recommend that our Users review our policy from time to time to ensure that they are informed of any updates. If necessary, we may notify Users by email of changes to this policy.


​    16. Contact

If you have any questions for us, please feel free to contact us:


Effective date: January 1st, 2023

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