Updated: March 1, 2019
This Policy does not extend to our customer’s use of information which is governed by their own privacy policies. To the extent we have access to your customer information through the use of our subscription services, we will employ the security and privacy measures indicated in our customer contract.
If you have any questions about the Policy, please contact us directly before entering any information by sending an email with your questions to our Privacy Officer.
INFORMATION WE COLLECT
We collect two types of information through our Website: “Personal Information” and “Non-personal Information”. Personal Information means information about an identifiable individual, such as your name and email address. Non-personal Information consists of aggregate information or any information that does not reveal your identity. The types of information we collect depend on the nature of your interaction with us.
We understand the importance of protecting your Personal Information. We are committed to appropriately handling and safeguarding your Personal Information.
HOW WE COLLECT INFORMATION
Information you provide. The types of Personal Information we may collect about you include your name, address, email address, and telephone number, and if you transact business with us, financial information such as your payment method (valid credit card number, type, expiration date, or other financial information), and other information incidental to the provision of the Services by us.
Information about others. We may collect and store personal information about other people that you provide to use, such as their name, address, and email address.
We use optional cookies: in order to collect usage data through Google Analytics to ensure you get the best experience on our website
We use necessary cookies: in order to store your cookie preferences.
Google Analytics. We also use third party cookies from Google Analytics to collect information about use of the Website. Google Analytics allows us to keep our website relevant by helping us understand how people use the Website. The information collected by Google Analytics is anonymous and only used for statistical purposes, and it helps us to analyse patterns of user activity and to develop a better user experience. Google Analytics cookies do not provide us with any Personal Information.
Opt-Out. You may opt out of such display advertising at any time by visiting your Google Ads Settings page or by installing and running the Google Analytics Opt-out Browser Add-on. Most computer and some mobile web browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set. Refer to your browser help menu for further information. Please note however that, by blocking or deleting cookies, you may not be able to take full advantage of the Website. If you do not want to receive tracking pixels, you will need to disable HTML images in your email client, and that may affect your ability to view images in other emails that you receive.
Information from mobile devices. If you use any mobile device to access the Website and download any of our applications, we may collect device information (such as your mobile device ID, model, and manufacturer), operating system and version information, and IP address. We may collect your location-based information (geolocation).
We also use “cookies” to collect information and make improvements to the Website. A cookie is a small data file that we transfer to your device. We may use “persistent cookies” to save user ID's and login passwords for future logins to the Website. We may use “session ID cookies” to enable certain features of the Website, to better understand how you interact with the Website and to monitor aggregate usage and web traffic routing on the Website. However, none of this is associated with you as an individual. It is measured only in aggregate. Cookies do not capture your individual email address or any private information about you. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the sites you visit. If you do not accept cookies, however, you may not be able to use all aspects of the Website.
We may use technologies, such as “web beacons” and other similar technologies, to track your use of the Website. We also may include web beacons in advertisements or email messages to determine whether messages have been opened and acted upon. The information we obtain in this manner enables us to customize the Services we offer our Website or application visitors to deliver targeted advertisements and to measure the overall effectiveness of our online advertising, content, programming or other activities.
HOW WE USE THE INFORMATION WE COLLECT
We may collect, use, and disclose your Personal Information for a number of different purposes:
• deliver our products and Services, and manage our business;
• manage your account and provide you with customer support;
• perform research and analysis about your use of, or interest in, our products, services, or content, or products, services, or content offered by others;
• communicate with you by email, postal mail, telephone, or mobile devices about products or services that may be of interest to you from us;
• develop and display content and advertising tailored to your interests on the Website and other sites, including providing our advertisements to you when you visit other sites;
• perform ad tracking and site or mobile application analytics;
• enforce or exercise any rights in our customer contract;
• perform functions as otherwise described to you at the time of collection;
• provide customer support to assist you with your questions or complaints;
• conduct surveys in order to improve the Website;
• advise you of changes to the Website, or new services that we may implement from time to time;
• measure and improve the effectiveness of the Website or our marketing endeavours;
• detect and protect against fraud and error;
• track and analyze your preferences to better understand your service needs and eligibility;
• to consider employees and members of our team; and
• for other purposes as described in this Policy.
When you choose to provide us with your Personal Information you consent to the use of your Personal Information as identified in this Policy and as may be further identified at the time of collection. Sometimes you will be asked to give your express consent to our collection, use, or disclosure of Personal Information (for example, by being asked to check a box to indicate your consent to receive marketing communications). You may also provide your implied consent to our collection, use, or disclosure of Personal Information when we can reasonably conclude that you have given consent by some action you have taken or an action you have decided not to take.
You may notify us at any time that you wish to withdraw or change your consent to our use and disclosure of your information. We will accommodate your request subject to legal and contractual restrictions.
ACCESS TO YOUR INFORMATION
If you have an online account with us, you have the ability to review and update your Personal Information online by logging into your account. If you have an online account with us, you also may delete or disable your account at any time by visiting the "Settings" page for your account. If you delete or disable your account, we may still retain certain information associated with your account for analytical purposes and record keeping integrity, as well as to prevent fraud, collect any fees owed, enforce our customer contract, take actions we deem necessary to protect the integrity of the Website or Users, or take other actions otherwise permitted by law. In addition, if certain information has already been provided to third parties as described in this Policy, retention of that information will be subject to those third parties' policies.
You may also request access to personal information we hold about you by written request to our Privacy Officer.
YOUR CHOICES ABOUT COLLECTION AND USE OF YOUR INFORMATION
You can choose not to provide us with certain information, but that may result in you being unable to use certain Services because such information may be required in order for you to register for the Services; purchase Services; ask a question; or initiate other transactions on the Website.
When you register on the Website, you may consent to receive email messages from us. You can choose to no longer receive commercial or promotional emails from us by submitting this request to firstname.lastname@example.org. You may be given the opportunity, in any commercial email that we send to you, to opt out of receiving such messages in the future. We request a reasonable time to process an opt-out request. Please note that changing information in your account, or otherwise opting out of receipt of promotional email communications, will only affect future activities or communications from us. If we have already provided your information to a third party (such as a service provider) before you have changed your preferences or updated your information, you may have to change you preferences directly with that third party.
We retain your Personal Information for as long as necessary to fulfill the purpose(s) for which it was collected and to comply with applicable laws, and your consent to such purpose(s) remains valid after termination of your relationship with us. Your Personal Information may be processed and stored outside of the province in which you reside or outside of Canada by us, an affiliate, or an unaffiliated service provider for the purposes set out in this privacy statement and, under the laws of these other jurisdictions, in certain circumstances foreign courts, law enforcement agencies or regulatory agencies may be entitled to access your personal information.
We may use third party service providers (for example, web hosting providers, data management providers, or payment processers) to manage one or more aspects of our business operations, including the processing or handing of Personal Information. When we do use an outside company, we use contractual or other appropriate means to ensure that your Personal Information is used in a manner that is consistent with this Policy.
By providing your payment to us, we will use the payment information you provide to bill you for goods and services. By providing your direct debit or credit card details to us, you consent to and authorize us to provide your direct debit or credit card details to payment processors and financial institutions necessary to process your payment.
To provide increased availability of the Website, some of these operations may result in Personal Information collected by us being stored outside Canada and, as a result, such personal information stored outside of Canada may be accessible to law enforcement and regulatory authorities in accordance with applicable laws of countries outside Canada.
We protect Personal Information in our files and document management systems from loss, misuse, unauthorized access, and alteration by using physically secure facilities, password protection, standard security practices and tools, and well-defined internal policies and practices.
FOLLOW-UPS AND SURVEYS
From time to time, we may send you a follow-up letter to thank you for your use of the Website, or we may contact you to ensure that you are completely satisfied. We may use contact information collected online to conduct occasional surveys and other customer research. These surveys are entirely voluntary and you may easily decline to participate.
INFORMATION SHARED AMONGST OUR AFFILIATES, SUBSIDIARIES, AND DIVISIONS
We may share Personal Information gathered on the Website with and amongst our corporate subsidiaries, affiliates, or divisions for internal business purposes in accordance with this Policy. If we do, we will ensure that your information continues to be used only in accordance with this Policy and your expressed choices.
DISCLOSURE REQUIRED BY LAW
We may disclose your information as permitted or required by law. For example, we may be compelled to release information by a court or other person or entity with jurisdiction to compel production of such information. If we have reasonable grounds to believe information could be useful in the investigation of improper or unlawful activity, we may disclose information to law enforcement agencies or other appropriate investigative bodies.
REQUESTS FOR ACCESS TO AND CORRECTION OF PERSONAL INFORMATION
Applicable privacy laws allow any individual the right to access and request the correction of errors or omissions in his or her Personal Information that is in our custody or under our control. This includes identification of Personal Information under our custody or control and information about how Personal Information under our control may be or has been used by us. We will respond to requests within the time allowed by applicable privacy laws and will make every effort to respond as accurately and completely as possible. Any corrections made to Personal Information will be promptly sent to any organization it was disclosed to.
You may request access to personal information we hold about you by written request to our Privacy Officer.
We will provide access to such Personal Information, subject to exceptions stipulated or required by applicable privacy legislation.
You may also make a complaint about our information and privacy practices to the Information and Privacy Commissioner at:
Office of the Privacy Commissioner of Canada
30, Victoria Street
Gatineau, QC K1A 1H3
1 (800) 282-1376
CHANGES TO THIS POLICY
We reserve the right to update this Policy at any time.