Privacy Policy

Last updated: November 3, 2023

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your Personal Data when You use the Service and tells You about Your privacy rights and how to exercise them.

This Policy also applies to data processed or hosted by us on behalf of the Utility. We will work with our clients to ensure their compliance with any applicable privacy law in regards to the hosted data.

We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions


The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.


For the purposes of this Privacy Policy:

  • Account means a unique account created for You to access our Service or parts of our Service.
  • Utility means an entity that is our customer. They act as a data controller and use your data for their business processes in accordance with their own privacy policies.
  • Application means the software program provided by the Company downloaded by You on any electronic device, named The Service, OR software operated by the Utility to provide their service to you.
  • Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to SpryPoint Services Inc., 401-25 Queen St. Charlottetown PE C1A 4A4.
  • Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
  • Country refers to: United States, or Canada, depending on where you are located. If you are located elsewhere, Canada is assumed.
  • Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
  • Personal Data is any information that relates to an identified or identifiable individual.
  • Service refers to the Application or the Website or both.
  • Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
  • Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
  • Website refers to the corporate website, accessible from
  • You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain Personal Data, including:

  • Email address
  • First name and last name
  • Phone number
  • Address, State, Province, ZIP/Postal code, City

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:

  • Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.
  • Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser. Learn more about cookies on the Privacy Policies website.

We use both Session and Persistent Cookies for the purposes set out below:

  • Necessary / Essential Cookies Type: Session Cookies Administered by: Us Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.
  • Cookies Policy / Notice Acceptance Cookies Type: Persistent Cookies Administered by: Us Purpose: These Cookies identify if users have accepted the use of cookies on the Website.
  • Functionality Cookies Type: Persistent Cookies Administered by: Us Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.

Use of Your Personal Data

The Company holds data for the Utility. We will never sell account holder data, it is not ours. As such We may ONLY use Personal Data for the following purposes:

  • To provide and maintain our Service, including to monitor the usage of our Service.
  • To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
  • For the performance of a contract: the development, compliance and undertaking of the contract for the products, items or services You have purchased or of any other contract with the Utility through the Service.
  • To contact You: To contact You by email, telephone calls, SMS, or other forms of communication, regarding information related to billing, collections, service orders, or alerts (e.g. boil water notice, planned maintenance outages) when necessary.
  • To manage Your requests: To attend and manage Your requests to the Utility.
  • For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of the Utility’s promotional campaigns, to evaluate and improve our Service and Your experience.

We rely on one or more of the following legal grounds (as appropriate) to process Personal Data:

  • To enter and perform a contract with You or to perform any steps You require from Us before entering into a contract.
  • To pursue Our legitimate business interests in establishing, managing or concluding our relationship with You.
  • Where You have consented to us processing Your Personal Data, or where an exception to the requirement to obtain consent applies.
  • To comply with Our legal obligations and establish, exercise or defend Our legal rights.

Where Personal Data is processed with consent, You may (subject to contractual and legal restrictions) refuse to provide Your consent, or choose to withdraw Your consent, to Our processing of Your Personal Data by contacting us as described below. Note that if you refuse to consent, or withdraw Your consent, to certain processing of Your Personal Data, we may not be able to provide certain of our services.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to provide the services requested, comply with our legal obligations (for example, if We are required to retain Your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

EU Citizens: We will work with the Utility to comply with GDPR.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Utility’s operating offices and in any other places where the parties involved in the processing are located. Where possible the data center where the data is held is in the same region as the Utility. However in some cases this information may be maintained on computers located outside of Your state, or province. Our hosted Data will never leave its country of origin to guarantee the data protection laws of Your jurisdiction.

Disclosure of Your Personal Data

Service Providers

We may share Your Personal Data with Service Providers who perform certain functions on our behalf. For example, bulk bill mailers will need Your mailing address. Please see “Detailed Information About Service Providers” section below.

Business Transactions

If We or the Utility is involved in a merger, acquisition or asset sale, or if the Utility chooses a different vendor for The Service, Your Personal Data may be transferred.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency). In some cases we would not be allowed to notify you or the public that a request has been made.


The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

  • Comply with a legal obligation
  • Protect and defend the rights or property of the Company
  • Prevent or investigate possible wrongdoing in connection with the Service
  • Protect the personal safety of Users of the Service or the public
  • Protect against legal liability

The Company may disclose Your Personal Data where you have specifically requested that we do so, or otherwise provided your consent to the disclosure.

Security of Your Personal Data

The security of Your Personal Data is important to Us. We take steps to protect Your Personal Data in our custody or control from unauthorized access, use or disclosure by using reasonable physical, organizational and technological security measures, including by encrypting Personal Data at rest and in transit and ensuring that access to Personal Data is limited to our authorized personnel and service providers who require access for the purposes of this Privacy Policy. We have internal procedures and policies regarding Our processing of Personal Data to facilitate our compliance with this Privacy Policy and applicable laws . If you are an App user, ensure you use a strong password with Multi-Factor Authentication and biometrics like fingerprint or facial recognition, if possible. No system or security measure is completely secure. Any transmission of Your Personal Data to Us is at Your own risk.

Detailed Information About Service Providers

The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies.

SMS / Email Delivery

We use Twilio and Sendgrid as SMS and Email Service Providers to manage and send texts/emails to You related to the Utility service.

Twilio’s Privacy Policy can be viewed at

Sendgrid’s Privacy Policy can be viewed at

Usage, Performance and Miscellaneous

We use third-party Service Providers to continuously improve our Service.

SolarWinds Papertrail

Papertrail is an application logging and service management tool by Solarwinds.

SolarWinds’ Privacy Notice:


Raygun is an application performance monitoring tool used to ensure the best user experience We can provide.

Raygun’s Privacy Policy:


FreshDesk is a customer support software. The service is operated by Freshworks, Inc.

The information gathered by FreshDesk is held in accordance with its Privacy Policy:

Your Rights

You may request access, updating or correction of Your Personal Data (subject to limited exceptions prescribed by law), or ask any questions about how We have processed Your Personal Data in our control by submitting a written request to our Privacy Officer (see “Contact Us” below). We may request certain Personal Data to verify Your identity. Please note that if Your request relates to Personal Data that we process on behalf of a Utility, You must make your request to the Utility directly.

Children’s Privacy

Our Service is not intended for or directed at anyone under the age of 14. We do not knowingly collect personally identifiable information from anyone under the age of 14. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 14 without verification of parental consent, We take steps to remove that information from Our servers.

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

This Privacy Policy is effective as of the “Last updated” date above. We may update Our Privacy Policy from time to time. We will notify You of any changes, including by posting the new Privacy Policy on this page or letting you know via email.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, would like to exercise any of Your rights with respect to Your Personal Data, or have any questions or complaints with respect to Our management of Personal Data, You can contact our Privacy Officer by email: