The information we collect is governed by United States ("US") law. By accessing or using our Products or otherwise providing information to us, you consent to the processing and transfer of information in and to the US and other countries.
1. Information We Collect
When you use our Products, we collect the following types of information:
(a) (a) Account information: When you use our Products you may need to create an account with us. In order to create an account, you will need to provide us with login credentials (which include your username and password), your name, email address, postal address, and phone number.
(b) General usage data: When you use our Products we may collect technical properties of hardware and software you use in conjunction with our Products. For example, we may collect the type and model of hardware and/or web browser you are using, referring or exit web pages, and the operating system version you are using.
When you use our Products we may also collect information about how long you use our Product in each session, features you use in our Products, how long you use our Products overall, the time and day you accessed our Products, etc.
We may record mouse clicks, movements, and other interactions with our pages or features to help us improve usability.
(c) Purchase and Payment Information: While payments made through our Products are processed through a third party, we may collect information to administer, manage, and fulfill the purchases you make. For example, we may collect your name, email address, account information, what is ordered, the date and time of the order, the quantity and price of the order, whether payment was made, method of payment, purchase history, and if you re-ordered.
(e) Third party information: If necessary to fulfill our identified purposes, we may combine the information you submit to us with information obtained from other sources or third party offerings. For example, we may receive personal information about you from third parties involved in providing you with the products, services, hardware, software, and websites you are utilizing, such as from your email, social media, and online file storage provider to facilitate the integration of those products, services, software, and websites with our Products. We treat all such personal information in accordance with this Policy and the terms and conditions between us and such third parties, if any, may also apply. However, the third party's own use of your personal information in such cases will be determined by your agreement(s) with the third party, unless that third party is one of our service providers.
(f) Quality assurance and customer service: Your customer service telephone calls and emails with us and our service providers, if any, may be recorded, logged, and/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 our Products and customer service. As part of the recording and logging of the calls and emails, we will collect information like the identity of the caller or sender of email, the date and time of the call or email, and the subject and resolution of the issue.
Some of this information would not by itself identify you to us or be personally identifiable and is therefore considered non-personal information. If we combine any such non-personal information with other personal information available to us, the combined information will be treated as personal information in accordance with this Policy.
2 Our Use of Information We Collect
We use the personal information we collect about you:
(a) to understand and meet your needs and preferences, and/or to provide you with our Products, for example:
(i) for purposes related to the billing, activation, provision, maintenance, support, troubleshooting, resolving of disputes, deactivation, upgrade, or update of Products;
(ii) to process and fulfill your order, send you emails to confirm your order status and shipment, send you Products or goods you order, and allow you to pay for Products and goods you order;
(iii) to ensure Products are technically functioning as intended and to help identify and troubleshoot issues;
(iv) to fulfill or enforce any agreements or notices we provide and are associated with a particular Product (“Notices”);
(v) to manage or respond to your inquiries;
(vi) to help us and our merchants create the best product and content mix for your preferences;
(vii) to personalize Products to your preferences;
(b) to develop new and enhance existing Products including to communicate with you about them using various means, for example to make available or send to you upgrades or updates, or notices of upgrades or updates of Products;
(c) to manage and develop our business and operations, for example;
(i) to detect, monitor, investigate, mitigate or attempt to prevent fraud and technical or security issues or to protect our property;
(ii) to allow for business continuity and disaster recovery operations;
(iii) to enforce our legal rights;
(iv) for statistical purposes;
(v) if we believe your actions are inconsistent with the spirit or language of our user agreements or policies;
(vi) In connection with, or during negotiations of, any merger, sale of our assets, financing, or acquisition of all or a portion of our business to another entity;
(d) to meet legal and regulatory requirements and to respond to emergency situations, for example:
(i) to respond to court orders, warrants or other lawful requests or legal processes;
(ii) to provide emergency assistance in situations that may threaten the life or physical safety of you or others; or
(iii) 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.
Notwithstanding anything to the contrary contained in this Policy, we may remove personal identifiers from your information and maintain and use it in a de-identified form that may be combined with other information to generate aggregated information. Such de-identified and/or aggregated information will be deemed to be owned by us and we shall have unrestricted title, rights, and interest to the de-identified and/or aggregated information which may include, without limitation, the right to use, distribute, transmit, transfer, license, trade, rent, share, assign, and sell the de-identified and/or aggregated information. We will retain your personal information as long as necessary for the fulfillment of the identified purposes or as otherwise necessary to comply with applicable laws.
You may update your communication preferences anytime by writing us at email@example.com.
3 To whom we Disclose your Personal Information
In accordance with this Policy, we may share your personal information:
(a) within Company and/or with our service providers such as a cloud service provider in Canada, the United States, and the European Economic Area for data storage;
(b) with our financial, insurance, legal, accounting or other advisors that provide professional services to us;
(c) if we have your consent;
(d) with third parties involved in providing our Products to you which may include authorized resellers, distributors, and merchants of record or payment processors, including companies like Facebook, Google and Swrve;
(e) and any and all information about your use of the Products with your employer or its agents if your employer has provided you with access to the Products;
(f) as necessary to complete any transactions while using our Products;
(g) respond to a subpoena, order, legal process, or government request;
(h) protect, establish or exercise our legal rights or defend against legal claims;
(i) investigate, detect, suppress, prevent or take action regarding illegal or prohibited activities, suspected fraud, situations involving potential threats to the reputation or physical safety of any person;
(j) as otherwise required by law; or
(k) if we are to be sold, merged, or amalgamated or substantially all of its assets are to be sold or disposed of, your personal information may be transferred to a potential purchaser if, and to the extent necessary, it is required for the purposes of deciding whether to proceed with the proposed transaction and completing it. If such a sale, merger, acquisition, or disposal is completed, we will use reasonable efforts to direct the transferee to use personal information you have provided to us in a manner that is consistent with this Policy. Following such a sale or transfer, you may contact the entity to which we transferred your personal information with any inquiries concerning the processing of that information.
4 Your Decisions About Your Personal Information
At any time you can contact us to: stop receiving emails from us; review the personal information held by us in connection with your account; withdraw your consent for our use and disclosure of your information; request a list of third parties to which we may have provided your personal information; close your account; and amend your personal information, by writing to us at 111 George Street, Suite 200, Toronto, Ontario, M5A 2N4. You can always unsubscribe from receiving promotional emails from us by simply clicking the “unsubscribe” link provided at the bottom of every promotional email from us.
If you contact us to do any of the things listed above, we may require you to provide sufficient personal information to allow us to identify you and tell you about the existence, use and disclosure of your personal information and this personal information will only be used for this purpose. If you contact us about your personal information, we will respond to your request within a reasonable time and at minimal cost or no cost to you in accordance with applicable laws.
Generally, you may withdraw at any time your consent for us to collect, use, and disclose your personal information in accordance with this Policy, subject to legal or contractual restrictions and reasonable notice. As such, we may continue to collect, use, and disclose your personal information as may be required to provide you with our Products, and to the extent that we are contractually obligated to do so or as necessary to enforce any contractual obligations you may have with us. If you refuse to provide us with the information we require or later contact us to withdraw your consent for us to use and disclose your personal information, we may no longer be able to provide you with our Products.
When you visit the Platform, we collect certain information by automated means, such as through server log files, cookies (text files sent to and stored on your device when you access the Platform), web beacons (also known as clear GIFs and pixel tags, which may be used to transmit information back to the Platform), and embedded scripts (programming code that is designed to collect information about your interactions with the Platform, such as the links you click on, and which is active only when you are accessing the Platform).
The information we collect in this manner may include details about the computer, mobile phone, or other device used to access the Platform (such as browser type, operating system, and IP address), referring URLs and information on actions taken or interaction with our digital assets.
We may use third-party web analytics services to help us analyze how visitors use the Platform. We may permit these third parties to operate directly on the Platform, use their own technology (such as cookies or web beacons), and collect information about you on our behalf.
The information we collect in this manner is collected to enhance your user experience. For example, this information allows us to pre-fill form fields as well as provide you with contextual recommendations while using the Platform.
When you visit our Platform, we may allow some third parties (such as advertising networks and data analytics companies) to collect information about your online activities over time and across different websites. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and online services you visit. However, there is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, we currently do not alter our practices when we receive a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” visit http://www.allaboutdnt.com.
In some instances, we may also combine information we receive about you from third parties with information we collect through the Platform.
Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, our web applications, mobile applications, or certain features thereof, may no longer function.
We aim to provide you with a safe experience. We have in place certain physical, technical, and administrative safeguards designed to appropriately protect the security and privacy of your personal information against loss, theft, and unauthorized access, disclosure, copying, use, or modification. Please note, however, that we cannot guarantee that the measures we maintain will guarantee the security of the information.
We limit access to your personal information within the Company to individuals with a need to know.
Your personal information may be collected, used, processed, transferred, and retained in multiple countries including Canada, the United States, and the European Economic Area 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, by using our Products, 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 us.
7 Links to Other Sites
8 Children’s Online Privacy Protection
The Platform and Products are not intended for use by children under 18 years of age. We do not knowingly collect or use any personal information from any children under 13 years of age. If we become aware that we have unknowingly collected personal information from a child under the age of 13, we will make commercially reasonable efforts to delete such personal information from our database.
9 Questions or Comments
If you have any questions or comments or wish to make a complaint about this Policy, please feel free to contact us by delivery in person, by courier or by the mail, to us at 111 George Street, Suite 200, Toronto, Ontario, M5A 2N4 or by email at firstname.lastname@example.org. If you contact us about your personal information, we will respond to your request within a reasonable time and at minimal cost or no cost to you in accordance with applicable laws. Depending on the circumstances and applicable laws, we may refuse to process certain access requests (for example, access requests that are unreasonably repetitive or systematic, would be extremely impractical or require disproportionate technical effort).
10 (For California Residents) Your California Privacy Rights
California law permits residents of California to request certain details about how their information is shared with third parties for direct marketing purposes. If you are a California resident and would like to make such a request, please email us at [insert e-mail address]. However, please note that under the law, services such as ours that permit California residents to opt in to, or opt out of, this type of sharing are not required to provide such information upon receiving a request, but rather may respond by notifying the user of his or her right to prevent the disclosure. To opt out of having information about you shared with third parties for direct marketing purposes, please email us at [insert e-mail address].
(For Nevada Residents) Your Nevada Privacy Rights
If you are a Nevada resident who visits our website you may review and request changes to any of your personal information that is collected on our website. Please refer to paragraphs 1(c)-(e) for information regarding information available to third party from your activities on our website. To exercise this right, please e-mail us at [insert e-mail address]. Any revision to this Notice required by changes to Nevada law will be posted on this website, so you are advised to review each time there is an update posted.
Effective Date: ______, 2017`