Effective as of April 02, 2022
Personal information may include, for example, a person’s name and home address, phone number, your child’s date of birth and gender, personal health information (e.g. health history, health conditions), a person’s occupation, a person’s personal financial records or credit information, or any personal identification numbers, or other identifying information.
We collect personal information that you voluntarily provide; for example, when you submit an image or other submission, use our App or Services, create an account, or contact us. Personal information we collect may include contact information (such as your first and last name, address, e-mail address, and phone number); payment card information; professional information (such as your company name and title), and any other information you directly provide to us in connection with submitting using our App or Services.
When you use our App, we also may collect various non-personal information (i.e. information which is not used to identify you or any other person), including, but not limited to, the date and time you access our App, any website from which you linked to our App, IP address, your operating system and browser type, and information about the type of device you use to access our App or Services. Such information is used for a variety of purposes such as operating and improving our App and Services, analyzing demographic and statistical research about App and Service usage, and monitoring the App and Services for compliance with our terms of service and the law, as well as for other purposes, as described in this Policy.
Any and all images you provide to us must not identify any child or be useable to identify any child or other person.
This non-personal information may be collected through various technologies, including but not limited to cookies and web beacons.
Company may, from time to time, use “cookies” solely for security and authentication purposes. Cookies are small pieces of data which are stored on your computer or smart device to allow your Internet browser to remember something about a website and/or Services. At your option, you may turn off Company’s “cookies” using the applicable features contained in your Internet browser; however, doing so may prevent you from accessing all or part of Company’s App or Services. To readjust your Internet browser’s cookies options, refer to the applicable instruction documentation for your particular Internet browser.
Company may, from time to time, engage third parties to assist with the App or Services, and such third parties may track your usage, locate your geographic position, collect personal information, send messages to you on behalf of Company, push notifications to you, and use “cookies”, as discussed herein.
Company may use web beacons alone or in conjunction with cookies to compile information about you and your usage of the App. Web beacons are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular website tied to the web beacon, and a description of a website tied to the web beacon. For example, we may use web beacons to operate and improve the App and Services. We may use information from web beacons in combination with personal information about you to provide you with information about us and our products and Services
Personal Information Use
We may use both personal and non-personal information that we collect from you for our business purposes. For example, we may use your information in the following ways:
- To evaluate proposals submitted to our website;
- To provide you with more relevant advertising and consumer education content;
- To respond to your messages and requests;
- To operate, maintain, and improve our App and Services, including to maintain security;
- For our statistical, research, recordkeeping, and reporting purposes;
- To personalize and improve your experience when you use our App and Services;
- For any other purpose identified at the point of collection.
Privacy legislation requires Company to obtain the consent of an individual to the collection, use or disclosure of personal information in many circumstances.
When Company receives personal information from you for the purposes of providing you with Company’s Services or for other uses identified herein by Company, you are providing Company with consent as follows:
- to allow Company to deal with that personal information in a reasonable manner;
- to allow Company to provide your personal information to third parties it engages to provide or support Company’s App or Services;
- to allow Company to use and store your personal information for the purpose of providing you with the App and Services you obtain from Company; and
- to allow Company to transfer your personal information outside of Canada (whereby your personal information will be treated in accordance with applicable foreign laws) for the purpose of storage and/or processing of your personal information.
If you provide Company with personal information about other individuals, you represent and warrant to Company that, where required by law and prior to your disclosure to Company, you will obtain the consent of each individual to the collection, use and disclosure by Company for the specific purpose(s) that the disclosure is made by you.
Providing Company with your personal information is always your choice. When you request or use the App and/or Services from Company, or register with Company’s App, Company asks that you provide information that enables Company to respond to your request and/or provide you with Company’s Services. In doing so, you consent to Company’s collection, use and disclosure to appropriate third parties of such personal information for these purposes.
There are legal exceptions whereby Company will not need to obtain consent or explain the purposes for the collection, use or disclosure of personal information. Some examples of situations where consent is not required include an emergency that threatens the life, health or security of an individual, or if Company must comply with a court order or governmental order.
We do not share personal information with unaffiliated third parties other than as follows:
- With government entities including in connection with evaluating proposals, or as needed to provide our App or Services and where required by law;
- With our affiliates and service providers;
- Pursuant to a subpoena, court order, or other legal process;
- To investigate, respond to, or resolve problems or inquiries (including law enforcement requests) or to protect, enforce, or defend our rights, assets, and/or interests;
- As part of an acquisition or merger with another company, a partial or total sale of assets, or another corporate change, including at bankruptcy;
- To prevent or respond to a violation of any law, regulation, or our terms of service; or
- With your consent or as otherwise disclosed at the time of collection.
Third Party Websites and Apps
Disclosure of Personal Information
In certain circumstances, Company may be required to provide personal information to third parties for legal or regulatory purposes. For example, under certain exceptional circumstance Company may have a legal duty or right to disclose personal information without the individual’s knowledge or consent. Various government agencies such as the Canada Revenue Agency, Human Rights Commission, Ontario Ministry of Finance; Ontario Ministry of Labour, etc. and law enforcement, have the authority to review our files and interview our staff when deemed necessary. These agencies have their own strict privacy obligations.
Marketing & Interest-Based Advertising Choices
You may choose how we contact you for marketing-related communications. You may request not to receive marketing from Company by sending an email to firstname.lastname@example.org. or by using the “Unsubscribe” link in any marketing email you receive from us. We may still contact you for some purposes as permitted by applicable laws.
We have third-party advertising partners that may collect information about your use of our App in order to provide advertisements to you on our Apps. Some of those ads may be interest-based, meaning that they are intended to be relevant to you based on the information these ad networks collect about your use of our App and Services over time.
To find out more about interest-based advertising and/or to opt out of the use of your information for this purpose, you may visit www.aboutads.info/choices.
Please note that if you use a different Internet browser or disable cookies on your browser, you may need to renew your opt-out choices, or may be unable to use all or parts of our App or Services.
Company does not knowingly collect personal information from visitors to our App under the age of majority in the jurisdiction of such visitor. In the event that we learn that we have collected personal information from a child under the applicable age of majority without verification of parental or legal guardian consent, we will delete that information.
Retention and Destruction of Personal Information
The amount of time Company will retain personal information varies, depending on the Services Company has provided and the nature of the personal information that Company holds. Company retains personal information for such period of time as is necessary for Company to maintain sufficient information so Company may respond to any issues that arise at a later date or as is required by law.
When personal information is no longer required by Company or by law, Company will either convert it into an aggregated non-identifying form or Company will appropriately destroy or erase the personal information in a manner that is in accordance with Company current policies and procedures.
Safeguarding Personal Information
Company employs reasonable physical, electronic and procedural safeguards that are designed to protect Company’s systems and personal information under Company’s control against unauthorized access and use. In accordance with appropriate industry standards in Canada, all safety and security measures are appropriate to the sensitivity level of the information collected.
Company may engage third party external servers as well as other external services, including cloud services and cloud compatible servers, and Company does not have any control over such external servers or services.
The Company may communicate with you via email and may use unencrypted plain text or html-based emails or messages when communicating with you. These emails or messages, and other electronic means by which Company may communicate with you, may contain information that is confidential, unless you instruct Company not to send such information electronically. Some Services may not be available to you if you instruct Company not to send some types of emails or electronic communications to you. Company may communicate with you through other electronic means, in accordance with the contact information you provide to Company.
While Company makes every effort to secure all electronic communications within Company’s control, there are inherent risks involved with exchanging information electronically. For example, such information may be accidentally or deliberately intercepted by third parties. Company is unable to accept any responsibility or liability for any damages you may suffer as a result of the interception, alteration or misuse of any information during any electronic exchange of such information.
Company will endeavour to be compliant with Canada’s Anti-Spam laws (“CASL”) in Company’s commercial electronic communication with you. Should you fail to provide Company with the requisite consent to send you commercial electronic messages, or withdraw such consent, Company may be unable to provide, or continue to provide, the App or some of Company’s Services that can only be provided if Company receives appropriate and required personal information. CASL consent can be provided or withdrawn at: email@example.com.
Keeping Information Accurate / Access and Correction
It is important to Company that your personal information held by Company is accurate and complete. Having accurate information about you enables Company to give you better service. You can help Company keep personal information up-to-date by keeping Company informed of any changes, such as a change of address, telephone number or any other circumstances.
With some exceptions, Company has the right to access, verify and amend the information Company has about you after Company has received your written request and authenticated your identity.
Company may charge a reasonable fee for providing information in response to an access request, and, upon request, Company will provide an estimate of any such fee upon receiving a request to access information. Company may require a deposit for all or part of the fee.
Where applicable or permitted, Company will make the information available within 30 days or provide written notice when Company requires additional time to respond to a request for access to information.
In some situations, Company may not be able to provide access to certain personal information as the right to access personal information is not absolute. If Company does not provide you with the requested information, Company will notify you in writing and explain Company’s reason(s) for not fulfilling your request.
Despite Company’s efforts, errors sometimes do occur. If you identify any personal information that is out-of-date, incorrect or incomplete, let Company know and Company will make the corrections promptly and use every reasonable effort to communicate these changes to other parties who may have inadvertently received incorrect or out-of-date personal information from Company. Company will note errors, incomplete information or unresolved differences in information collected in any file it has relating to you.
Withdrawal of Consent
You may, at any time, withdraw your consent to Company’s collection, use and disclosure of your personal information, subject to reasonable notice and any legal and/or contractual restrictions.
Should you choose to withdraw your consent, Company may be unable to provide, or continue to provide, the App or some of Company’s Services that can only be provided if Company receives appropriate and required personal information. Consequently, should you choose not to provide Company with the required personal information, Company may be unable to offer the App and such Services to you.
If you have questions regarding our privacy or information practices, please contact us at firstname.lastname@example.org.
Successors and Assigns