1-844-963-2583

2533595 Ontario Inc. operating as BlueBranch, Inc. (the “Company”) 

Privacy Policy 

Date Last Modified: March 15th, 2023 

 

NAVIGATION 

  1. Introduction
  2. Data Collection
  3. Data Management
  4. Data Usage
  5. List of Third Party Processors

 

  1. INTRODUCTION TO PRIVACY POLICY

The Company is committed to maintaining the confidentiality, integrity and security of any Personal Information (as defined below) about Company’s Users. To demonstrate Company’s commitment to protecting Your privacy, Company has developed this privacy policy (“Privacy Policy”), which describes how Company will collect, use, disclose and protect Your Personal Information through the Product.  

COMPLIANCE WITH LEGISLATION 

In Canada, the Company is a service provider and may act as a service provider, information manager or electronic service provider under applicable privacy legislation (the “Applicable Laws”). 

The Company may use and disclose personal information if it is required to do so by Applicable Laws, when it is permitted or if the Company has a good faith belief that such action is necessary to conform to Applicable Laws or comply with any legal, regulatory or similar requirement or investigation, to protect or defend the rights or property of the Company or another user or to enforce the Company’s License Agreement. 

The Company is dedicated to safeguarding the personal information under our remit and in developing a data protection regime that is effective, fit for purpose and demonstrates an understanding of, and appreciation for the General Data Protection Regulation (EU) 2016/679 (“GDPR”). Our preparation and objectives for GDPR compliance have been summarized in this statement and include the development and implementation of new data protection roles, policies, procedures, controls and measures to ensure ongoing compliance.

a) LICENSE AGREEMENT AND LICENSE AGREEMENT

This Privacy Policy as well as the Company’s Terms of Use (“License Agreement”) govern Your access and use of the Product, as owned and operated by the Company, a company incorporated provincially in Ontario (referred to in this Privacy Policy as the “Company”). Terms capitalized but not defined in this Privacy Policy have the meanings set out in the License Agreement. “You”, “Your” and “Yours” refers to you, the “User” or “End-User”, or if You are a company that is registering for user accounts on behalf of Your employees or contractors, as defined in the License Agreement.

b) CONSENT AND AGREEMENT TO BE BOUND

(i) CONSENT PROVIDED BY CONTINUING USE. By accessing and/or using the Product You agree to all the terms and conditions of this Privacy Policy and the License Agreement which are incorporated here by reference. If You do not agree to all the terms and conditions of this Privacy Policy and the License Agreement, please do not use the Product.

(ii) YOU MAY ALSO HAVE PROVIDED CONSENT THROUGH DISTRIBUTION PLATFORMS. There are certain types of device data that the Product cannot access without Your consent. The various application marketplace platforms that the Company serves the Product through will notify You the first time the Product requires permission to access certain types of data and will let You decide to consent to that request. You further agree to abide by all third party terms, end user licensing agreement, or any other applicable application store (“Distribution Platforms”) agreement, so long as such agreement does not conflict with the terms herein or the License Agreement. 

 (iii) CHANGES WILL REQUIRE YOUR CONSENT. In the case of a material change to the Product as described in the amendment provision set out in the License Agreement, and in accordance with the amendment requirements set out therein, the Company will provide written notice to inform You and will obtain consent from You for any new purposes not previously identified. 

 (iv) PROVIDING CHANGES TO YOUR CONSENT. Changes can be submitted by updating Your data in accordance with the user data update and verification provisions set out in the section of this Privacy Policy entitled 3. Data Management. 

(c) CONSENT TO COLLECTION AND ANALYSIS OF THE INFORMATION YOU PROVIDE TO US

(i) SPECIFIC CONSENT TO COLLECTION OF INFORMATION. By using the Product, You consent to the collection, use and disclosure of Your Personal Information by the Company in the manner described in this Privacy Policy. You may always opt not to disclose certain Personal Information, but which may restrict access to certain features of the Product. For example, Your name and email address, along with your Registration Information (as defined in the License Agreement) are necessary to complete the registration process. At any time after registration, You may opt out of most email communication from the Company by clicking on the opt-out link at the bottom of Company’s emails, or by contacting the Company at the contact details listed above. However, the Company may still contact You for administrative purposes. Withdrawing consent will not apply to actions the Company has already taken based on Your prior consent. 

 (ii) CONSENT TO PROCESS THIRD PARTY DATA YOU SEND TO US IS YOUR RESPONSIBILITY. Any data sent to the Company for processing by You is considered to be third party data (“Third Party Data”). For all Third Party Data, consent required upon collection of third party data shall be obtained by You (“Third Party Data Consent”). 

 (iii) CONSENT TO RECEIVING COMMUNICATIONS FROM US: When You sign up for an account, You are opting in to receive emails from the Product for administrative or technical issues and You may occasionally receive the Company newsletters. 

 

COMMUNICATIONS IN THE EVENT OF BREACH: In the unlikely event that Company confirms that the security of Your Personal Information in the Company’s possession or control may have been compromised and creates a real risk of significant harm to You, or if the Company believes that a notification is appropriate, the Company may seek to notify You of that development, pursuant to both the Company’s desire to keep You informed and Company’s legal requirement to do so. If a notification is appropriate, the Company may notify You by the email address registered to Your account. Additional details on a Data Breach can be found in the section of this Privacy Policy entitled 3. Data Management. 

 (iv) WE WILL NOT REQUEST CONFIDENTIAL PERSONAL INFORMATION: Company will never send email messages to customers requesting confidential information such as passwords, credit card numbers, or social security or social insurance numbers. Please do not act on any such emails as You may compromise Your Personal Information by replying or by following links to a fraudulent website.   

 (d) AMENDMENTS TO THIS PRIVACY POLICY AND VALIDATION TO CONFIRM COMPLIANCE WITH LAW.

The Company may amend or change this Privacy Policy at its sole discretion at any time, and in accordance with the amendment provisions set out in the License Agreement. The use of the information the Company collects at any given point is subject to the Privacy Policy in effect at the time of collection. If the Company makes any material changes the Company will notify You by email or by means of notice on the Product prior to the change becoming effective. The Company will post the most current Privacy Policy on the Product, and Your use of the Product is subject to the most current Privacy Policy as posted on the Product at any time.

(i) COMPANY’S PERIODIC REVIEW. The Company will perform a periodic and timely review to ensure that the Company’s Privacy Policy is compliant with Applicable Laws.  

 (ii) YOUR PERIODIC REVIEW. The Company encourages You to periodically check the Company’s Privacy Policy for the latest information on the Company’s current policy.

(e) DISCLAIMER 

IF YOU CHOOSE TO ACCESS THE PRODUCT, YOU DO SO AT YOUR OWN RISK, AND ARE RESPONSIBLE FOR COMPLYING WITH ALL LOCAL LAWS, RULES AND REGULATIONS. WE MAY LIMIT THE AVAILABILITY OF THE PRODUCT, IN WHOLE OR IN PART, TO ANY PERSON, GEOGRAPHIC AREA AND/OR JURISDICTION WE CHOOSE, AT ANY TIME AND IN THE COMPANY’S SOLE DISCRETION. THE COMPANY’S PRIVACY POLICY DOES NOT COVER THE INFORMATION PRACTICES OF OTHER COMPANIES AND ORGANIZATIONS WHO ADVERTISE THE COMPANY’S SERVICES, AND WHO MAY USE COOKIES (DEFINED BELOW) AND OTHER TECHNOLOGIES TO SERVE AND OFFER RELEVANT ADVERTISEMENTS. SEE COMPLETE SECTION 14 (LIMITATION OF LIABILITY) AND SECTION 10 (DISCLAIMERS), AND SECTION 6 (PROHIBITED USES) CONTAINED IN THE LICENSE AGREEMENT. 

INFORMATION YOU SHARE WITH THIRD PARTIES. You should be aware that by providing third parties with Your name (User ID) and password, You may inadvertently enable unauthorized persons to review, modify or delete Your personal information. The Company cannot monitor the use of the Product.

(f) MINORS 

The Product is not intended for children under 18 years of age, and the Company does not knowingly collect or sell Personal Information from children under 18. If You are under 18, do not use or provide any information on the Product or through any of its features. If the Company learns they have collected or received Personal Information from a child under 18 without verification of parental consent, the Company will delete it. If You are the parent or guardian of a child under 18 years of age whom You believe might have provided us with their Personal Information, You may contact us using the below information to request that it be deleted.

(g) INTERNATIONAL USERS 

The Product is controlled and operated by the Company from Ontario, Canada and is not intended to subject the Company to the laws or jurisdiction of any state, country or territory other than that of Ontario, Canada. Any information You provide to the Company through use of the Product may be stored and processed, transferred between and accessed from either: (1) Ontario, Canada, or (2) other countries/jurisdictions that have similar privacy standards as those in Ontario, Canada, but which may not guarantee the same level of protection of personal data as the jurisdiction in which you reside. However, the Company will handle Your Personal Information in accordance with this Privacy Policy regardless of where your Personal Information is stored/accessed.  

(h) MISCELLANEOUS 

If any portion of this Privacy Policy is deemed unlawful, void or unenforceable by any arbitrator or court of competent jurisdiction, this Privacy Policy as a whole shall not be deemed unlawful, void or unenforceable, but only that portion of this Privacy Policy that is unlawful, void or unenforceable shall be stricken from this Privacy Policy. The insertions of headings are for convenient reference only and are not to affect the interpretation of this Privacy Policy.

(i) CONTACT INFORMATION 

If You have questions or concerns regarding Company’s policy or practices, please contact Company’s privacy officer by email at: info@bluebranch.ca.  

 (j) EFFECTIVE DATE.  

This Privacy Policy is effective as of the Effective Data as defined in the License Agreement. 

 

NAVIGATION 

  1. Introduction
  2. Data Collection
  3. Data Management
  4. Data Usage
  5. List of Third Party Processors

2. COLLECTION OF USER INFORMATION INCLUDING PERSONAL INFORMATION

(a) DISCLOSURE OF COLLECTION 

Within this section of the Privacy Policy, the Company will provide You with notice that Your information is being collected when You first sign into the Product. In the section of this Privacy Policy entitled 3. Data Management, the Company will be describing the manner in which Your information is managed, and in the section of this Privacy Policy entitled 4. Data Usage, You will also be notified about the nature for which the data will be used, how the Company processes the data, and how the Company works with third party service providers who will assist the Company to process the data.

(b) COLLECTION OF PERSONAL INFORMATION 

When You use the Product, the Company stores and collects certain information about Your computer or device and Your activities that You provide to the Company and that the Company automatically collects, including: 

(i) REGISTRATION INFORMATION: Your user Registration Information (as defined in the License Agreement) and which may include any of the following personal information (“Personal Information”): first and last name, address, location, email address, certifications or training qualifications, contract number, your list of skills, resume and licensing data (if applicable);

(ii) TECHNICAL INFORMATION: technical information about Your device such as the type of device, mobile device identification number, IP address of Your computer, web browser, OS version, location, other browser information (e.g., size, connection speed and connection type) and operating system or platform;

(iii) USER PREFERENCES COLLECTED AUTOMATICALLY: Your User Preferences which Company will collect and determine automatically through Cookies and traffic data as described below; 

(iv) DEMOGRAPHIC INFORMATION; platform use information and analytics;

(v) YOUR INTERNET PROVIDER or mobile carrier name; and

(vi) USER PREFERENCES SUPPLIED BY YOU: Your user experience preferences and settings (time zone, language, etc.), as well as content and usage preferences (collectively, the “User Preferences”).

(c) METHODS OF COLLECTION 

We may collect electronic information from You from the following sources:

(i) COLLECTION OF INFORMATION AT REGISTRATION. Registration is required if You want to use the Product. As part of this registration, the Company will require that You submit certain Registration Information (as defined in the License Agreement) that is relevant to the purposes of the Product;

(ii) COLLECTION THROUGH SOCIAL MEDIA: If You are logged into social media websites or applications (such as Facebook, Instagram, Twitter, among others, and individually and collectively, “Social Media Services”) on pages and/or locations that are related to Company’s Product, Company may receive information from such Social Media, in which case Company may collect and store information identifying Your account with the Social Media Services;

(iii) COLLECTED THROUGH COMPANY’S COMMUNICATIONS WITH YOU: via email or through the Product, through messages or transaction information relating to Your use of the Product, through other User-generated content provided to the Company in the normal course of Your use of the Product, including but not limited to communications related to registration, evaluations, internal surveys, feedback information, usage information, correspondence with the Company through technical support tools and/or email, by Traffic Data (as described within this Privacy Policy); and 

(iv) COLLECTED AUTOMATICALLY THROUGH ANALYTICS TOOLS: The Company may collect and store information (including Personal Information) locally on Your device using mechanisms such as Product data caches, “Cookies” (cookies, pixel tags or other similar technologies which are small data files that are stored on a User’s device for record-keeping purposes that track where You travel on the Product and what You look at, on single sessions or cumulated over time. Although Cookies are used by most major Products and are accepted by default by most Products, it may be possible to disable Cookies via Your settings), and through “traffic data” which collects the route and destination of users and information on and through Company’s Product, as well as cookies that are stored temporarily on Your device.

(d) PROCESSING OF COLLECTED INFORMATION 

In the section of this Privacy Policy entitled 4. Data Usage, You will also be notified about the nature for which the data will be used, how the Company processes the data, and how the Company works with third party service providers who will assist the Company to process the data. 

NAVIGATION 

  1. Introduction
  2. Data Collection
  3. Data Management
  4. Data Usage
  5. List of Third Party Processors 

 

3. DATA MANAGEMENT

(a) VALIDATION AND CHANGES TO COMPANY’S USER-INFORMATION

(i) VALIDATION: The Company may validate the Personal Information, if the employer User has requested this service. If applicable, Company may validate Personal Information to the extent contracted with the employer User and any discrepancies discovered may be corrected or disclosed. 

(ii) CLIENTS COLLECTING INFORMATION ON BEHALF OF THEIR USERS. In the case that the User Personal Information is provided to the Company by one of the Company’s clients, the Company will accept that database as verified and accurate. If the Company is collecting the data on behalf of the Company’s client, the Company will work with the User to ensure that processes will be put in place to ensure that Users are given the chance to review and correct any data issues.

(iii) REVIEW OF INFORMATION AND INDIVIDUAL ACCESS. The Company relies on You to ensure that the Personal Information You enter into the Company’s system is as accurate, complete and up-to-date as necessary for the purposes for which it is to be used. Until the Personal Information Removal Date (as defined below), You may review or update Your Personal Information by submitting a request to review or update Your Personal Information to info@bluebranch.ca indicating that You are requesting such review or update, subject to the identity verification process set out below, and with the understanding that the Company may make changes to Your Personal Information to meet the technological requirements of the Company’s networks and media. Unless required to comply by law, the Company may reject access or modification requests that are unreasonably repetitive, require disproportionate technical effort, risk the privacy of others, or would be extremely impractical. Where the Company can provide information access and correction, and when required by law, the Company will do so for free. 

(iv) REMOVAL OF YOUR PERSONAL INFORMATION BY US OR BY YOU: At any time and up to ninety (90) days after Your License Agreement with Company has been terminated or the maximum time period allowed by Applicable Law as described below, whichever is longer (this is the “Personal Information Removal Date”) the User may request a copy of all of the User’s Personal Information from the Product. After the Personal Information Removal Date, or upon Your specific request to info@bluebranch.ca to delete the Personal Information, such Personal Information shall be deleted by Company within a reasonable period, unless:

A. INFORMATION MAY BE RETAINED UNTIL A SYSTEM-WIDE BACKUP IS PURGED: such data may continue to temporarily persist in the Company’s system-wide business recovery back-ups (if any) until such time as the system-wide business recovery backup is deleted and replaced with data that does not include data collected during Your agreement term; however, You have no expectation of data retention whatsoever and acknowledge that backing up of Your own data is Your responsibility; or

B. INFORMATION MAY BE RETAINED IF REQUIRED TO COMPLY WITH LAW: such data may continue to temporarily persist to the extent that such information is required to be retained for compliance with Applicable Law (for example, to prevent, investigate, or identify possible wrongdoing in connection with the Product or to comply with legal obligations) and until such time as such information is no longer required for this purpose, however, You acknowledge that recovery of data is not permitted by You from within this system under these circumstances unless the Company is required and compelled to do so by law, and in such event, at Your sole expense.

(v) CHANGE REQUESTS MAY REQUIRE IDENTITY VERIFICATION ON YOUR PART: When updating Your Personal Information, the Company may ask You to verify Your identity before the Company can act on Your request.

(vi) TRACKING YOUR PREFERENCES. The Company may capture and manage all User privacy preferences. Their preferences may be tracked in the database and attached to Your User records. If the preferences are changed, the modifications may be incremental, and added to an audit log. Tracking of Your consent to the collection, storage and use of Your Personal Information may also be recorded for the purposes of an audit log for consent. 

(b) STORAGE AND RETENTION

(i) INDIVIDUALS DATA RETENTION:  

a. OF NON-PERSONAL INFORMATION: Data that is non-Personal Information may be kept by the Company for an indefinite period however, this does not constitute a guarantee that the Company will keep the data indefinitely. If a User would like to ensure that data is indefinitely kept, that can be requested, upon written agreement of the parties of a custom services plan. This data will primarily be used in aggregate and anonymized format to drive business intelligence and analytics. 

b. OF PERSONAL INFORMATION: Personal Information data will be kept until the Personal Data Removal Date (as defined above), with such deletion to be initiated by the Company or by the User, in the manner described above in the section entitled “Removal of Personal Information By Company or by You.” You should have no expectation of data retention whatsoever. From time to time the Company will create a backup of all data in the Company’s system. This backup is for use by the Company only in the case of disaster recovery or to maintain business operations in the case of an emergency. No data will be backed up (except for such disaster recovery purposes and the Company’s internal usage). Backing up of Your own data is Your responsibility.

c. DATA RECOVERY BY YOU: Other than information that Company is required to retain and provide to You by law, 

d. DATA RESTORES: The Company will not restore data unless it is available and then only if the Company determines, in its sole discretion that a data recovery is necessary.

e. PERIODIC AUDIT. Company may perform routine audits at its sole discretion or on a schedule as required by Applicable Law to confirm deletion of the data has occurred in the manner described above in the section entitled “Removal of Personal Information By Company or By You.”

(ii) BUSINESS’ DATA RETENTION AND ACCOUNT TERMINATION: Clients of the Company who are businesses/companies may terminate their account by pressing the unsubscribe button located in the settings tab of their business dashboard panel. After ninety (90) days, or the longest period allowed by law, of receiving a termination request, the business profile, including all offered promotions, will be removed from the Product, but the Company may retain Personal Information about You for the purposes authorized under this Privacy Policy and the License Agreement unless prohibited by law. For example, the Company may retain information to prevent, investigate, or identify possible wrongdoing in connection with the Product or to comply with legal obligations.

(c) SECURITY MEASURES: The Company takes Your privacy very seriously. If You have a security related concern, please contact the Company at the contact details provided above. The Company will work closely with You to ensure a quick and personal response to Your concerns. In addition, the Company restricts unauthorized access through protective policies, procedures, and technical measures, including:

(i) SAFEGUARDS PROVIDED BY YOU: To keep Your Personal Information secure, You are required to safeguard Your User name and password information in accordance with the License Agreement.

(ii) SAFEGUARDS PROVIDED BY US: The Company may provide physical and electronic safeguards with regards to the storage of Personal Information as required by law, however, and pursuant to the disclaimer provided in the License Agreement, You understand that in order for the Company to operate the Product, User Data may be transmitted by You to the Company over the internet, public networks or otherwise, and You acknowledge that no such data transmission can be guaranteed to be completely secure, and that, beyond the Company’s requirements to provide a warranty on information security as required by law or in accordance with the security protocols agreed to by the parties hereto in writing, the Company cannot warrant the security of any information You transmit to us, and that You do so at Your own risk.

(iii) ACTIONS IN THE EVENT OF DATA BREACH. A “Data Breach” is defined as any non-authorized access to the storage locations of the data, or access to a storage location by an individual that is potentially suspected of having performed non-authorized activities. In the case where a Data Breach has occurred, if the Company believes that the breach creates a real risk of significant harm to the users, the User will be notified in the manner as required by law, and all details regarding the impact to the User will be shared.

(iv) To keep Your Personal Information secure, You are required to safeguard Your subscriber name and password information in accordance with the License Agreement.

(d) TRAINING COMPANY’S STAFF IN DATA MANAGEMENT:

(i) TRAINING OF COMPANY’S STAFF FOR HANDLING PERSONAL INFORMATION: Company’s employees and contractors may be required to adhere to standards and policies to ensure that Personal Information is secure and treated with the utmost care and respect. Furthermore, Company may limit access to Your Personal Information to those employees or contractors who Company reasonably believe need to come into contact with that information in order to do their jobs and Personal Information will only be reviewed if anonymized or otherwise accessed on a “need-to-know” basis.  

 (ii) EMPLOYEE COMPLIANCE. All employees may need to read and attest to having read this Privacy Policy. Furthermore, as this Privacy Policy is evergreen, any time material changes are made to the document, employees may need to attest to having read and understand the changes to the document. From time to time, training may be provided to employees on this Policy Privacy and privacy issues required to be compliant with the applicable law.  

NAVIGATION 

  1. Introduction
  2. Data Collection
  3. Data Management
  4. Data Usage
  5. List of Third Party Processors 

4. DATA USAGE SCHEDULE TO THE PRODUCT LICENSE AGREEMENT

(a) USE AND DISCLOSURE OF PERSONAL INFORMATION. Company will not use or disclose Personal Information other than the purposes identified below (individually and collectively, the “Purpose”):

(i) TO COMMUNICATE WITH YOU AND TO PROVIDE CUSTOMER SERVICE: To provide customer service and support, administrative messages, updates, and security alerts, to resolve disputes, and to troubleshoot problems;

(ii) TO IMPROVE COMPANY’S PRODUCT: To fulfill Your requests or the Company’s product roadmap for certain features of the Product, to customize, measure, and improve the Product including by analyzing trends, tracking user movements on the Product, gathering demographic statistics about the Company’s user base as a whole, and to assist the Company to measure the Company’s performance and effectiveness of the Company’s content, and to share the Company’s performance information with others;

(iii) TO FULFILL COMPANY’S BUSINESS GOALS: to directly or indirectly offer or provide You with products and services that are based on the Company’s analysis of Your needs as determined by the Company’s analytics and the analytics of the Company’s third-party processors, unless You opt out; 

(iv) TO ENABLE  COMPANY’S COLLABORATORS TO FULFILL THEIR  COMPANY’S  BUSINESS GOALS: Where a third party to this Privacy Policy directly or indirectly provides the Company with the ability to provide the Product to You, the Company may supply Personal Information to such Third Party in exchange for fulfilling the Company’s Purpose and providing corresponding value to the third party, and such third parties are listed in Section 5 of this Privacy Policy entitled “List of Third Party Processors”; 

(v) IN THE EVENT OF AN ACQUISITION OF COMPANY. In the event that the Company, or all or a portion of the Company’s business, or one or more of its divisions, is acquired by one or more third parties as a result of an acquisition, merger, sale, reorganization, consolidation, liquidation or another similar transaction, Your Personal Information shall be one of the transferred assets. To the extent that the Company is required to do so by law, You will be notified of any changes in ownership or uses of Your Personal Information.

(vi) TO ENABLE COMPANY’S PARENT COMPANY OR AFFILIATED COMPANY’S BUSINESS TO FULFILL THEIR BUSINESS GOALS: The Company may share information from or about You with subsidiaries, joint ventures, or other companies under common control, in which case the Company will require them to honor this Privacy Policy. 

(vii) TO ENFORCE  COMPANY’S  LICENSE AGREEMENTS AND TO COMPLY WITH LAW: (1) to enforce the Company’s rights against You or in connection with a breach by You of this Privacy Policy or the License Agreement; (2) to investigate or respond to suspected illegal or fraudulent activity or to protect the safety, rights, or property of us, the Company’s users, or others; (3) to prevent prohibited or illegal activities; (4) to prevent situations involving potential threats to the physical safety of any person; or (5) when required by any applicable law, rule, regulation, subpoena, or other legal process.

(viii) TO PROCESS PAYMENTS: To use certain services on the Product, Company or third parties may require debit or credit card account information (“Debit or Credit Card Information”). By submitting Your Debit or Credit Card Information through the Product to the Company, You expressly consent to sharing of Your information with third-party payment processors and other third-party service providers. In the event that you share your Debit or Credit Card Information with a third party, you acknowledge and agree that you will be bound by such applicable third party terms and conditions, as applicable. 

(ix) TO PROVIDE SERVICES TO USERS: The Company makes the Product available to Users for a variety of uses, as described in the License Agreement. In order to provide the Product to our Users, the Company collects certain Personal Information such as contact and Registration Information from the User.

(x) And to fulfill other purposes related to Company’s Product, subject to Your explicit consent if consent is required by law.

(b) USE OF COOKIES AND USAGE DATA: The Company may use session Cookies and usage data to fulfill the Purpose, by tracking information about You as related to Your usage of the Product and correlating to other personally identifiable information collected while on the Product or connected to Company’s third party processors (as listed in Section 5 to this Privacy Policy entitled List Of Third Party Providers). The Company may also use Cookies that are created by the Product to secure Your login session and to help ensure the security of Your account. 

(c) USE OF THIRD PARTIES TO ASSIST US TO IMPROVE THE PRODUCT AND TO ACHIEVE Company’s BUSINESS GOALS: To fulfill the Purpose, the Company may share Personal Information with the Company’s affiliates, acquirers or third-party collaborator or vendors (as listed in Section 5 to this Privacy Policy entitled List Of “Third Party Providers”), subject to the following conditions: 

(i) USE LIMITED TO SERVICE PROVIDED OR PURPOSE OF TRANSFER: Company’s service providers are restricted from using Your Personal Information in any way other than for the service they are providing or as it relates to the Company’s Purpose fulfilled by such transfer; this includes the use of Cookies by the Company’s third parties so long as the use on such Cookies is to collect the same type of information for the same purposes as the Purpose.

(ii) THIRD PARTIES MUST ADHERE TO COMPANY’S STANDARDS: The Company ensures that such third parties maintain reasonable and appropriate safeguards that do not breach the Company’s safeguards or security requirements set out in Section 3 of this Privacy Policy entitled “Data Management”, or as otherwise required by law. If the use of Cookies by any third party differs materially from the practices already listed, the Company will revise this document accordingly and notify existing users of the change(s).

(d) INTERNATIONAL DATA TRANSFER 

Pursuant to the Purpose set out in section 4(a) entitled “Use and Disclosure of Personal Information”, You agree that all information processed by the Company may be transferred, processed, and stored anywhere in the world, including but not limited to, the countries which may have data protection laws that are different from the laws where You live. The Company has taken appropriate safeguards to ensure that Your Personal Information will remain protected and require our third-party service providers and partners to have appropriate safeguards as well, including that all information be processed and stored in countries which have safeguards at least as strict as in the province of Ontario.

(e) RIGHTS TO CONTENT PROVIDED BY THE USER

(i) FOR INFORMATION YOU PROVIDE. By posting content on the Application (the “User Data”), the End-User and Client jointly hereby grants to the Company a worldwide, non-revocable, non-exclusive, perpetual, royalty-free, and sub-licensable right to use, create derivative works of, modify, and to distribute (including without limitation, distribution online, through multiple channels, and bundled with other applications or materials) such content, and further, the agrees to waive any moral rights to such User Data, and agrees that the Company may modify or adapt the User Data in order to transmit, display or distribute it over other applications and in various media. The Client and/or End-User agrees that the Client and/or End-User will individually and jointly defend, indemnify and hold harmless the Company from and against any Claims (as defined in the Agreement) arising from the nature of the content submitted and/or the ownership of End-User Data and any claims of infringement of third party intellectual property related to such End-User Data.

(ii) FOR INFORMATION WE AUTOMATICALLY COLLECT. The Company creates benefits to all of its Users by analyzing the Company Data for the purposes of Product improvements. The User agrees that the Company shall have the right to collect and analyze data and other information relating to the provision, use and performance of various aspects of the Company products and related systems and technologies, and the Company will be free (during and after the Initial Term or subsequent Renewal Term) to (i) use such information and data to improve and enhance the Company products generally, (ii) for other development, diagnostic and corrective purposes in connection with the Products and Services, and (iii) disclose such data solely in aggregate, anonymous, and non-identifiable form that is in no way connected User or its business.

(f) USE OF INDEPENDENT THIRD PARTY PROVIDERS. When using the Product, You may choose to interact with features from third parties that operate independently from the Company, such as links to third-party websites. The Company has no control over and is not responsible for the privacy practices of such third parties. This Privacy Policy does not apply to the extent the Company does not own or control any linked websites or features you visit or use. The Company recommends that You familiarize yourself with the privacy practices of those third parties. 

 

NAVIGATION 

  1. Introduction
  2. Data Collection
  3. Data Management
  4. Data Usage
  5. List of Third Party Processors

5. LIST OF THIRD PARTY PROVIDERS

(a) Google Cloud – https://cloud.google.com

(b) Docusign – https://www.docusign.ca

(c) Survey Monkey – https://www.surveymonkey.com

(d) Sovren –  https://www.sovren.com