Privacy Policy

Privacy Policy

Last Updated: July 15, 2024

Sponge Design Inc. developed the Hummingbird Platform, a mobile application designed to address conflicts between the wider public and at-risk individuals, while also delivering much-needed care to those with limited access. Our mission is to contribute to a more inclusive world. We believe in transparency and that starts with informing you about how we collect, use, and share your information, as well as your rights regarding that information when using the Hummingbird Platform.

This Privacy Policy describes how Sponge Design, Inc., (“we,” “us,” “our,” or “Sponge”), processes personal information in relation to your use of the Hummingbird Platform.


1. Definitions

Undefined terms in this Privacy Policy have the same definition as in our Terms and Conditions (“Terms”).

2. Information we collect

2.1 Information needed to access the Hummingbird Platform

We collect Information about you when you use the Hummingbird Platform. Without it, we might not be able to provide all the support requested. This information includes:

  • Contact, Account, and Profile Information. Such as your first name, phone number, email address, business name, business address, profile photo, the type(s) of services you are approved to provide, and qualifications (such as certifications and training), some of which will depend on whether you use the Hummingbird Platform to provide intervention support, or to request intervention support.

2.2 Information You Choose to Provide Us

You have the option to provide us with additional information on the Hummingbird Platform. The nature of this information varies based on whether you are a Help Seeker or an Outreach Worker.

  • Information provided by Help Seekers:
    • Ratings and feedback. When you rate and provide feedback about the Hummingbird Platform, including your experience with Outreach Workers or the Outreach Support received, we collect all the information you provide in your feedback.
  • Information provided by Outreach Workers:
    • Additional profile information. Such as why you do outreach work. This information as indicated in your account settings is part of your public profile page and will be publicly visible.
    • Information about the Outreach Support delivered in response to a request. When Outreach Workers take notes (“Notes“) about the assessment, intervention, outcomes, and any follow-up details upon the completion of an Outreach Support request, we collect all of the information provided in the Notes.
    • Client Personal Data. Outreach Workers may provide personal information about Clients, which includes Personal Information (as defined in the Personal Information Protection and Electronic Documents Act – PIPEDA) and Personal Health Information (as defined in Ontario’s Personal Health Information Protection Act – PHIPA). This combined information is collectively referred to as “Client Personal Data.” By providing such data, Outreach Workers certify that they have the authority and have obtained consent from Clients to share this data with Sponge for the explicit purposes outlined in this Privacy Policy. 
  • Information provided by all Users:
    • Other Information. Such as when you fill in a form, respond to surveys, communicate with Hummingbird support via email or the Hummingbird Platform, or share your experience with us. This may include health information if you choose to share it with us.

2.3 Information Automatically Collected When You Use the Hummingbird Platform

When you use the Hummingbird Platform, we automatically collect some of your personal information and other information. This information may include:

  • Geolocation Information. Such as precise or approximate location determined from your IP address, mobile or other device’s GPS, or other information you share with us, depending on your device settings. We may also collect this information when you’re not using the App if you enable this through your settings or device permissions.
  • Usage information. The information we collect about your use of the Hummingbird Platform depends on whether you use the Hummingbird Platform as an Outreach Worker or Help Seeker:
    • Help Seekers: We collect Outreach Support request information such as the date, time, location, description, type of request, and whether you cancelled the request.
    • Outreach Workers: For each Outreach Support request we collect information about the Outreach Worker’s activities, such as the time they accepted the request, dispatched, arrived at the request location, completed or cancelled the request. We also collect information about your interactions with the Hummingbird Platform, including the dates and times of when you switch online and offline.
  • Device Information. We collect information about the devices you use to access the Hummingbird Platform, including device OS, unique identifiers, device language, and the most recent timezone the device was in.
  • Third-Party Technologies. The Hummingbird Platform uses third-party technology providers to:
    • Facilitate your access to and the delivery of our Outreach Support;
    • Assist us in analyzing how you use the Hummingbird Platform and, thereby, improve your experience of our Outreach Support;
    • Monitor and analyze the performance, operation, and effectiveness of the Hummingbird Platform.

We want to inform you that these Third-Party Technologies also have access to your personal information. See the links below for information on what personal data is collected by our third-party technology providers and how they manage that data:

2.4 Information We Collect From Other Sources

  • Service Providers. If you use the Hummingbird Platform as an Outreach Worker, our Service Providers or the social organization with which you are affiliated may provide us with information about your qualifications as an outreach worker. This may include certifications, training details, and professional experiences. The purpose of collecting this information is to ensure the quality and safety of the Outreach Support facilitated by the Hummingbird Platform.
  • Other Users and Sources. Other users or public or third-party sources, such as law enforcement, media, or pedestrians, may provide us with information about you, for example, as part of an investigation into an incident, to provide you support, or as part of a complaint submitted about you.
3. How We Use Your Information

3.1 Provide, Improve, and Develop the Hummingbird Platform. We may process your personal information to:

  • Verify your identity and maintain your account, settings, and preferences;
  • Process your Outreach Support request;
  • Connect you to Outreach Workers and track the progress regarding your request;
  • Allow Users to connect regarding their Outreach Support request and to choose to share their location with others;
  • Send you messages, updates, security alerts, and notifications;
  • Collect feedback regarding your use of the Hummingbird Platform and experience;
  • Provide customer service training;
  • Perform analytics, debug, and conduct research;
  • Develop new features, partnerships, and services;
  • Prevent, find, and resolve software or hardware bugs and issues; and
  • Monitor and improve our operations and processes, including security practices, algorithms, and other modelling.

3.2 Create and Maintain a Trusted and Safe Environment. We may process this information to: 

  • Authenticate and verify information provided by you;
  • Detect and prevent fraud, spam, abuse, security and safety incidents, and other harmful activities;
  • Conduct fraud prevention, security investigations, and risk assessments;
  • Comply with our legal obligations, protect the health and well-being of our Help Seekers, Outreach Workers, Clients, and members of the public;
  • Comply with law, respond to legal requests, prevent harm, and protect our rights;
  • Determine eligibility for all Outreach Support requests;
  • Enforce our agreements with third parties;
  • Enforce our Terms and other policies (e.g., Community Guidelines);
  • Investigate and resolve disputes with Users;
  • Encourage friendly and safe interactions and avoid unsafe behaviour; and
  • Block and remove unsafe or fraudulent Users from the Hummingbird Platform.

3.3 Build and Maintain the Hummingbird Community. Sponge works to be a positive part of the community. We use your personal information to:

  • Communicate with you about recent events, accomplishments, and milestones achieved by the Hummingbird Platform; and
  • Provide content, experiences, and communications to grow the Hummingbird Platform.

3.4 Provide Customer Support. We work hard to provide the experiences possible, including supporting you whenever needed. To do this, we use your personal information to:

  • Investigate and assist you in resolving questions or issues you have regarding the Hummingbird Platform; and
  • Provide you support or respond to you.

3.5 Respond to Legal Proceedings and Requirements. Sometimes the law, government entities, or other regulatory bodies impose demands and obligations on us with respect to the Outreach Support we seek to provide. In such a circumstance, we may use your personal information to respond to those demands or obligations. 

4. How We Disclose Your Information

Sponge is committed to complying with all applicable privacy laws (“Data Protection Laws”), including without limitation the Canadian Personal Information Protection and Electronic Documents Act (“PIPEDA”), and the Personal Health Information Protection Act (PHIPA) in Ontario.

We do not sell your personal information to third parties for money — no one can buy the personal information we collect from and about you and we do not act as a data broker. However, our services and features require that we share data with other Users. We may also share such data with our partners, for quality assurance or legal reasons or in connection with claims or disputes. This section otherwise explains when, why, and with whom we disclose your information.

4.1 Sharing between Users. To surface the Outreach Support requests and facilitate the delivery of support, we share information between Users in situations such as:

  • Help Seeker information shared with Outreach Worker:
    • Upon an Outreach Worker accepting a request, we will share with the Outreach Worker (and any additional Outreach Worker they are paired with or request backup support from, if applicable) the Help Seeker’s name, phone number, and other information Help Seekers include in their request for support, such as request location and description;
    • If the request is cancelled by the Help Seeker, we will share with the Outreach Worker the Help Seeker’s reason for cancellation; and
    • When the request is either cancelled or completed, we also eventually share the Help Seeker’s rating and feedback with the Outreach Worker and any additional Outreach Worker they were paired with while working on your request. (We remove the Help Seeker’s identity associated with ratings and feedback when we share it with Outreach Workers, but an Outreach Worker may be able to identify the Help Seeker that provided the rating or feedback).
  • Outreach Worker information shared with Help Seeker:
    • Upon an Outreach Worker accepting a request, we will share with the Help Seeker the Outreach Worker and their partner’s names, profile photos, phone numbers, qualifications, real-time activity updates (like time of dispatch, estimated arrival time, and time of arrival) as well as other information the Outreach Workers choose to add in their profiles (like “why I do outreach”);
    • If the request is cancelled by the Outreach Worker, we will share the Outreach Worker’s reason for cancellation with the Help Seeker and any additional notes the Outreach Worker chooses to provide to the Help Seeker.
  • Between Outreach Workers:
    • We will share your online-offline status with other Outreach Workers, and when you are online and working on a request, we will share with other Outreach Workers the ID of the request you are working on and the progress of that request;
    • When you call other Outreach Workers for backup support, we will share with those other Outreach Workers your phone number; and
    • Information pertaining to Notes of a request, including assessment, intervention, outcomes, and follow-up details, will be shared with any additional Outreach Worker you were paired with for the request.

4.2 Sharing with Emergency Services. When you call 9-1-1 via the App to contact emergency services, your phone number will be shared with them. For more details on how they collect and use your personal data, please visit the Information and Privacy Commissioner of Ontario’s website at www.ipc.on.ca.

4.3 Complying with Law, Responding to Legal Requests, Preventing Harm and Protecting Our Rights. We may disclose your personal information in response to a legal obligation, or if we have determined that disclosing your personal information is reasonably necessary or appropriate to:

  • Comply with any applicable federal, state, or local law or regulation, civil, criminal or regulatory inquiry, investigation or legal process, enforceable governmental request, or requirement as condition to operate (e.g., operating permit, license or agreement);
  • Respond to legal process (such as a search warrant, subpoena, summons, or court order);
  • Enforce our Terms;
  • Cooperate with law enforcement agencies concerning conduct or activity that we reasonably and in good faith believe may violate federal, state, or local law; or
  • Exercise or defend legal claims, protect against harm to our rights, property, interests, or safety or the rights, property, interests, or safety of you, third parties, or the public as required or permitted by law.

4.4 Service Providers.

  • Personal Information of Help Seekers. We collaborate with Service Providers to enhance the quality of Outreach Support and improve the overall user experience on the Hummingbird Platform. This involves sharing certain personal information, usage data, and other information you choose to provide us, including your name, business address, request location and details, usage statistics (such as the number of requests), ratings, and feedback. The purpose is to refine Outreach Support, provide exceptional customer service, and conduct research for the ongoing development and improvement of the Hummingbird Platform. It’s important to note that our Service Providers are contractually obligated to safeguard your personal information.
  • Outreach Support Request Notes. Information pertaining to Notes of any Outreach Support requests, including assessment, intervention, and outcomes, may be shared with the Outreach Worker’s affiliated Service Providers. This sharing is conducted with the aim of refining the quality of Outreach Support, ensuring excellent customer service, and contributing to ongoing research for the advancement and enhancement of the Hummingbird Platform.
  • Outreach Worker Activities. We may share information about an Outreach Worker’s usage of the Hummingbird Platform, such as dates and times of when they switch online and offline, with their affiliated Service Providers to help ensure adherence to shift schedules. We may also share information about an Outreach Worker’s activities pertaining to individual requests, such as when they accepted the request, time of dispatch, estimated arrival time, and actual time of arrival. We disclose such information to their affiliated Service Providers with the aim to improve service processes and, thereby, the experience of both Outreach Workers and Help Seekers.
  • All Communications with Hummingbird Support. To ensure the quality and safety of the Outreach Support we facilitate, we share all information you provide us when you communicate with Hummingbird support via email or the Hummingbird Platform with our Service Providers, including:

4.4 Business Transfers. If Sponge undertakes or is involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer, or share some or all of our assets, including your information in connection with such transaction or in contemplation of such transaction (e.g., due diligence). In this event, we will notify you before your personal information is transferred and becomes subject to a different privacy policy.

4.5 Upon Your Further Direction. With your permission or upon your direction, we may disclose your personal information to interact with a third party or for other purposes.

5. How We Store and Protect Your Information

We retain your information for as long as necessary to provide you and our other users with the Hummingbird Platform. This means we keep your profile information for as long as you maintain an account. We retain requested Outreach Support information for at least seven years to ensure we can perform legitimate business functions, such as accounting for tax obligations. We also retain your information as necessary to comply with our legal obligations, resolve disputes and enforce our terms and policies. If you request account deletion, we will delete your information as set forth in the “Deleting Your Account” section below.

While no organization can guarantee perfect security, we are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unlawful or unauthorized access, loss, destruction, or alteration.

6. Your Rights And Choices Regarding Your Data

The Hummingbird Platform provides ways for you to access and delete your personal information as well as exercise applicable data rights that give you certain control over your personal information.

6.1 Profile Information. You can review and edit certain account information you have chosen to add to your profile by logging in to your account settings and profile. You are responsible for keeping your personal information up to date.

6.2 Push Notifications. You can opt out of receiving push notifications through your device settings. Please note that opting out of receiving push notifications may impact your use of the Hummingbird Platform (such as receiving a notification that your support has arrived).

6.3 Location Information. You can prevent your device from sharing location information through its system settings. However, doing so may affect Hummingbird’s capability to offer you our complete range of features and assistance.

6.4 Accessing Your Information. You can access the information we have about you by logging into your account and viewing your profile, saved address, and request history.

6.5 Deleting Your Account. You may delete your account and its data by requesting deletion of your account through contacting us at support@sponge.design, or by going to Profile in the App.

In some cases, we will be unable to delete your account, such as if there is an issue with your account related to trust, safety, or fraud. When we delete your account, we may retain certain information for legitimate business purposes or to comply with legal or regulatory obligations. For example, we may retain your information to resolve open insurance claims, or we may be obligated to retain your information as part of an open legal claim. When we retain such data, we do so in ways designed to prevent its use for other purposes.

6.6 Lodging a Complaint. You have the right to communicate with Sponge about any issues that you may have relating to your personal information.

Sponge Design Inc. is responsible for ensuring the Hummingbird Platform’s compliance with this Privacy Policy and Data Protection Laws. You should direct any complaints, concerns or questions regarding the Hummingbird Platform compliance in writing to Sponge at the contact information below in Section 9.

7. Children’s Data

Hummingbird is not directed to children, and we don’t knowingly collect personal information from children under the age of 16. If we find out that a child under 16 has given us personal information, we will take steps to delete that information. If you believe that a child under the age of 16 has given us personal information, please contact us at support@sponge.design.

8. Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time in accordance with applicable law. If we do so, we will post the revised Privacy Policy and update the “Last Updated” date at the top. In case of material changes, we will also provide you with notice of the modification by email before the effective date. If you disagree with the revised Privacy Policy, you can delete your Account. If you do not cancel your Account before the date the revised Privacy Policy becomes effective, your continued access to or use of the Hummingbird Platform will be subject to the revised Privacy Policy.

9. Contact Us

If you have any questions or concerns about your privacy or anything in this policy, including if you need to access this policy in an alternative format, we encourage you to contact us at support@sponge.design.