Effective June 9, 2021
1. The Ten Principles of PIPEDA Summarized
i. Accountability: organizations are accountable for the personal information they collect, use, retain and disclose in the course of their commercial activities, including, but not limited to, the appointment of a Chief Privacy Officer;
ii. Identifying Purposes: organizations are to explain the purposes for which the information is being used at the time of collection and can only be used for those purposes;
iii. Consent: organizations must obtain an Individual’s express or implied consent when they collect, use, or disclose the individual’s personal information;
iv. Limiting Collection: the collection of personal information must be limited to only the amount and type that is reasonably necessary for the identified purposes;
v. Limiting Use, Disclosure and Retention: personal information must be used for only the identified purposes, and must not be disclosed to third parties unless the Individual consents to the alternative use or disclosure;
vi. Accuracy: organizations are required to keep personal information in active files accurate and up-to-date;
vii. Safeguards: organizations are to use physical, organizational, and technological safeguards to protect personal information from unauthorized access or disclosure.
viii. Openness: organizations must inform their clients and train their employees about their privacy policies and procedures;
ix. Individual Access: an individual has a right to access personal information held by an organization and to challenge its accuracy if need be; and.
x. Provide Recourse: organizations are to inform clients and employees of how to bring a request for access, or complaint, to the Chief Privacy Officer, and respond promptly to a request or complaint by the individual.
2. Information We Collect
a. We collect the following categories of information, which may be considered personal information when maintained in identifiable form:
i. first name and surname, username and password, email address, contact information, country of residence, and other information you provide us when you create an account on the Site or use Services, sign-up to receive communications or materials from us, or otherwise submit a form to us;
ii. Usage, viewing, logs, metrics and other device and technical data collected when you visit our Sites, use the Optimizely Service as an end user, or open or reply to emails we send. This may include information such as your web request, Internet Protocol ("IP") address, device identifiers, device information (such as OS type or browser type), cookie IDs, referring / exit pages and URLs, interaction information (such as clickstream data), domain names, pages viewed, crash data, and other similar technical data;
iii. Location information when you visit our Site or use our Service, including location information either provided by a mobile device interacting with one of our sites or applications or associated with your IP address.
b. Users can also upload and/or share Testimonials providing their feedback, review and comments on the Services provided by Us.
3. How We Collect Information From You
a. We collect information from you when you submit it to us, for example, when you request products, services, or information from us, register for an account.
b. We may also;
i. automatically collect usage, analytics, viewing, logs, metrics and other device and technical data when you access our Site or use the Service as an end user. For example, when you access our Sites or log into the Service, our servers will automatically record certain information about your device and browser, and we may collect usage, clickstream, event data, crash data, and other technical data.
ii. automatically acquire information when you reply to or interact with an email we send, such as to track your engagement with our messages or when your replies to our messages contain additional email addresses.
c. The Testimonials, as mentioned in Section 2 (b), can be uploaded by the Users directly to the Site and/or such Testimonials can be directly interviewed by Us and subsequently uploaded.
4. How We Use Information
a. We may use the information collected to:
i. process your orders and requests and respond to your questions and concerns; for example, if you inquire about our services, we may use your data to respond to and process these requests;
ii. provide you with products and services, and personalize your experience;
iii. communicate with you about your account or transactions, and provide you with product-related communications, such as information about new features and policy updates;
iv. operate, maintain, analyze, develop, update and improve our Site, the Service, and other products and services we offer. For example, we may administer and track users' activities on our Sites and the Service to determine how to improve our content and features, or we may analyze trends and gather demographic information about our user base to better tailor our marketing efforts;
v. detect, investigate and prevent activities that may violate our policies, or applicable laws (such as fraud detection and prevention) or that may threaten the security, integrity or availability of our or another party's products, systems and services;
vi. The Testimonials uploaded/collected from the User will be collected and stored by Us indefinitely, and that such retained information may be used for advertisements, promotion, resolve disputes, provide customer support, troubleshoot problems, etc., and that such information, if requested, may be provided to judicial or governmental authorities of requisite jurisdiction, or otherwise used by Us as permitted by applicable laws.
5. Sharing Information with Others
a. We do not share your personal information except in certain circumstances, including:
i. To enforce our terms, agreements, policies or rules, to help protect the security, integrity and availability of our or another party's products, systems and services; to exercise or protect the rights, property (including intellectual property), our users, or others; to comply with legal requirements; or in other cases if we believe in good faith that disclosure is required by law (including in response to a lawful subpoena or other law enforcement request); and
ii. In connection with a sale, divesture, or transfer of our company (including any shares in the company) or any combination of its products, services, assets, affiliates, and/or businesses. Your personal information (such as customer names and email addresses, and user information related to the Service) may be among the items sold or otherwise acquired in these types of transactions. We may also sell, assign or otherwise transfer such information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions, reorganizations, liquidations, similar transactions or proceedings involving all or a portion of the company. You will be notified via email and/or a prominent notice on our Site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
b. We do not share your personal information with any third party entities except with payment processing and gateway companies.
6. Data Retention Policy
a. We will retain your information only for as long as is necessary for the purposes set out in this policy, for as long as your account is active, as described in this policy, or as needed to provide the Services to you. If you no longer want Us to use your information to provide the Services to you, you may close your account. We will retain and use your information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your information to comply with applicable tax/revenue laws), resolve disputes, enforce our agreements, and as otherwise described in this policy.
7. Limiting Collection
a. We limit the amount and type of personal information we collects to that which is necessary for the business of the utility and as permitted by law. Each of our affiliate will be responsible for its own collection, use and disclosure of information. Personal Information will be collected using procedures that are fair, transparent and lawful.
a. We shall take all reasonable steps to ensure that all personal information will be kept accurate, complete and up to date. Individuals may challenge the accuracy and completeness of personal information about them and have it amended, as appropriate.
a. In executing its responsibilities with respect to the confidentiality of personal information, we will employ a number of safeguards, appropriate to the sensitivity of the information, to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. Such safeguards will include physical measures, organizational measures and technological measures, for example locked filing cabinets, restricted access to offices, security clearances, limiting access on a “need to know” basis and the use of passwords and encryption. Procedures for implementing these measures will be communicated to all employees and third parties to ensure compliance with this principle.
a. We will make its policies and practices relating to the protection of personal information available to its customers. We will keep its customers informed of these policies and practices and customers shall be provided access to all related policies. The information will be available in a format that is easy to understand.
a. Any of Our customer can have access to the personal information about them that We have in our possession or control. Any customer may request that their personal information be amended for purposes of accuracy and completeness.
b. You can at any time contact our support at [email protected] to get your personal data deleted. You may also export your personal data to a CSV file either from inside the app or through our web service or by contacting us. If you need any further assistance regarding your rights, feel free to contact us at [email protected] .
c. Customers can make their requests by email [email protected] or in writing Suite #233, 200 Carnegie Drive, St. Albert, AB T8N 5A7, Attention: Privacy Officer). Response to an individual’s request will be made in a timely and efficient manner.