Last modified: March 5th, 2020
- What personal information do we collect about you and how do we collect it?
There are several types of information we collect about you:
- Information directly from you. We collect personal information you give us directly. For example, when you create an Account with us you will give us information like your email address, first and last name, business name, payment information, and your username and password. You may also provide us with other optional information as part of your Account profile, such as avatars or profile images, other contact information, and links to social network profiles you have (including when used for authentication purposes). We may also collect information directly from you for contractual or legal reasons. For example, we may ask you to select your jurisdiction when you sign up for Services to determine if, and how much, tax we need to collect from you. We’ll normally let you know when information is required, and the consequences of failing to provide it. If you do not provide personal information when requested, you may not be able to use our Services if that information is necessary to provide you with the service or if we are legally required to collect it.
- Communications. Personal information you include in your communications with us, such as information you include in SMS or RCS (text) messages, form submissions on the Website, and other electronic messages between you and us (collectively, “Electronic Messages”) or by phone or mail, and information you post on or through the public areas or features on our Website or in the Services.
- Information from your use of the Website and Services. We collect personal information about you when you use our Website and Services. This includes information like your Internet protocol (IP) address, your geographic location, the website you visited before coming to our Website, your browser type and settings, log data, your device information (for example, if you’re using a tablet, mobile phone, or desktop computer and the operating system), the date and time when you visited the Website, information about your browser configuration and plug-ins, your language preferences, and other unique identifiers, information about how you interact with the Website and Services, the information we collect when you complete a transaction with us through the Services, information you provide in the App to use its functions and features, and usage data you may provide to us through the communication and help and support systems through the Website and our Services.
- Marketing preferences, surveys, contests, or promotions. Information you include in your marketing preferences with us or that you provide as part of a survey, contest, or promotion that we run and in which you participate.
- Payment processing information. If you have made a purchase through us, or if you make a financial transaction using our Services, we and any third-party payment processors we use will collect information about the purchase or transaction. This includes billing details, credit card information, account, and authentication information.
- How do we use your information?
We use information that we collect about you or that you provide to us, including any personal information, for several purposes, as detailed below. Collecting this information may be necessary to provide our Services to you and without this information, we may not be able to provide all or some aspects of the Services to you. For example, information we collect to process payments, communicate with you, to customize your experience, to improve your customer experience, to make our Website and Services secure, to manage our relationships with third-parties that assist us with providing the Services, to enforce our rights and to meet our obligations, to comply with laws, and to meet the purposes for which you gave us the information are all vital and necessary to providing Services to you.
- To make our Website and Services available to you. We use your personal information to provide the Website and Services to you and to respond to your requests. We also use it to personalize our Services.
- To process payments. We use your personal information to process payments through our Website and Services.
- To communicate with you. We use your personal information to communicate with you, including to send you emails about the Services and your relationship with us.
- To market and promote our business to you. We use your personal information to market our Services and business to you, including through surveys and promotions. We may use your information to send you tailored marketing communications about products, services, offers, programs, and promotions of ours and those of our partners and measure the success of those campaigns. For example, we may send different marketing communications to you based on what we think may interest you based on other information we hold about you.
- To deliver advertisements to you. We use your personal information to analyze your interactions with our Website and Services and third parties’ services so we can tailor our advertising to what we think will interest you. For example, we may decide not to advertise our Services to you on a social media site if you already signed up for an Account or follow us, and we may choose to serve you a particular advertisement based on your service choices with us or what we think may interest you based on other information we hold about you.
- To improve our Website, Services, and customer experience. We use your personal information to analyze and learn about how you access and use the Website and Services, to evaluate and improve our Website and Services (including by developing new products and services and managing our communications), and to monitor and measure the effectiveness of our advertising. We usually do this based on anonymous, pseudonymized, or aggregated information which does not focus on you individually. For example, if we learn that most people using our Services in a location or for a particular purpose tend to use a specific integration or feature, we might wish to expand on that integration or feature.
- To make our Website and Services secure. We use your personal information to keep our Website and our Services secure, such as when we use your personal information to verify your identity and access credentials.
- To manage our third-party relationships. We use your personal information to manage our vendor and partner relationships.
- To enforce our rights and to meet our obligations. We use your personal information to carry out our obligations and enforce our rights under contracts, our terms of service, billing, or to comply with legal requirements. We may also use your personal information to protect our and others’ interests, rights, and property.
- To comply with the law. We use your personal information to comply with applicable legal requirements, such as tax and other government regulations, contracts, and law enforcement requests. We will also use your personal information to give you notices about your relationship with us.
- When do we use your information?
- Consent. You have consented to the use of your personal information in a particular way. When you consent, you can change your mind at any time.
- Performance of a contract. We need your personal information to provide you with services and products requested by you or to respond to your inquiries. In other words, so we can perform our contract with you or take steps at your request before entering into one. For example, we need your email address so you can sign-in to your Account.
- Legal obligation. We have a legal obligation to use your personal information at times, such as to comply with applicable tax and other government regulations or to comply with a court order or binding law enforcement request.
- Legitimate interests. We have a legitimate interest in using your personal information. In particular, we have a legitimate interest in the following cases:
- To operate our business and provide you with tailored advertising and communications to develop and promote our business.
- To analyze and improve the safety and security of our Website and Services. We do this as it is necessary to pursue our legitimate interests in ensuring our Website and Services are secure, such as by implementing and enhancing security measures and protections and protecting against fraud, spam, and abuse.
- To provide and improve the Website and Services, including any personalized services. We do this as it is necessary to pursue our legitimate interests of providing an innovative and tailored offering to our users on a sustained basis.
- To share your personal information with other companies that help us provide and improve the Website and Services.
- To anonymize and subsequently use anonymized information. Personal information does not include information that has been anonymized or aggregated in such a way that it can no longer be used to identify a specific natural person, whether on its own or in combination with other information. We may use your personal information to create this kind of anonymized or aggregated data.
- How do we share your personal information?
- Affiliates. We share personal information with our affiliates when it is reasonably necessary or desirable, such as to help provide services to you or analyze and improve the services we or they provide.
- Business partners. We may share personal information with our business partners. For example, we may share your personal information when our Website or Services are integrated with the services of other parties, but only when you have been informed or would otherwise expect such sharing.
- Service providers. We share personal information with our service providers that perform services on our behalf. For example, we may use third parties to help us provide customer support, manage our advertisements on other sites, send marketing and other communications on our behalf, or assist with data storage. We also use a variety of service providers in connection with the Website and Services. We only share your personal information when you have been informed or would otherwise expect such sharing.
- Process payments. We transmit your personal information via an encrypted connection to our payment processor.
- Following the law or protecting rights and interests. We disclose your personal information if we determine that such disclosure is reasonably necessary to comply with the law, protect our or others’ rights, property or interests or to prevent fraud or abuse. In particular, we may disclose your personal information in response to lawful requests by public authorities, such as to meet national security or law enforcement requirements.
- Our own advertising. We share personal information with third parties so we can provide you with tailored advertising for our business and measure and monitor its effectiveness. For example, we may share your actual or pseudonymized email address with a third-party social media platform on which we advertise to avoid serving ads to people who already use our Services.
- Third party advertising. We share personal information with third parties so they can provide you with tailored advertising regarding their business and measure and monitor its effectiveness. For example, we may allow third parties to post their advertisements on our Website or in our Services and those third parties may use your personal information to measure how those advertisements perform and to show you ads that you may be interested in.
- Business transfers. If we’re involved in a reorganization, merger, acquisition or sale of some or all of our assets, your personal information may be transferred as part of that deal or the negotiation of contemplated deals.
- Information we collect and share with or sell to others so they can market their products and services to you. Our business includes collecting information and data about people and companies that use our Website and Services, and using that data to gain insights, metrics, and information that other organizations, people, and companies may find useful in marketing their products and services. We may share or sell such information with others as part of our business and in connection with our Services. We only provide aggregated, non-personal, anonymized data unless we have your permission in advance, such as for verification of authenticity, to provide our Services to you, to follow up on your inquiries, or as disclosed at the time the information is collected.
- Your rights and choices.
- Rights to access, update, change, or delete personal information. Where applicable law requires (and subject to any relevant exceptions under law), you may have the right to access, update, change, or delete your personal information. You can access, update, delete, or change your personal information directly in your Account or by contacting us at email@example.com to request the required changes. You can exercise your other rights (including deleting your Account) by contacting us at the same email address. Please note that we may need to verify your identity in connection with your requests, and such verification process may, if you do not have access to your Account, require you to provide us with additional information (e.g. government identification). Even if you have access to your Account, we may request additional information if we believe it’s necessary to verify your identity. If we are unable to verify your identity or request, we may not, in accordance with applicable law, be able to fulfill your request. Please note that, for technical reasons, there is likely to be a delay in deleting your personal information from our systems when you ask us to delete it. We also will retain personal information in order to comply with the law, protect our and others’ rights, resolve disputes or enforce our legal terms or policies, to the extent permitted under applicable law.
- Commercial electronic messages. Like many other companies, we may ask you to sign up to receive emails and other Electronic Messages from us. If you no longer wish to receive those messages, you can opt-out by following the unsubscribe link in the messages or by contacting us.
- Data processing and portability. You may have the right to restrict or object to the processing of your personal information or to exercise a right to data portability under applicable law. You also may have the right to lodge a complaint with a competent supervisory authority, subject to applicable law. Additionally, if we rely on consent for the processing of your personal information, you have the right to withdraw it at any time and free of charge. When you do so, this will not affect the lawfulness of the processing before your consent withdrawal.
- European Union and General Data Protection Regulation (GDPR).
- Rights under European Union laws and GDPR. If you are located in the European Union, you have certain rights under European law with respect to your personal data, including the right to request access to, correct, amend, delete, port to another service provider, or object to certain uses of your personal data.
- Exercising your rights. If you wish to exercise these rights, please contact us. If you are unhappy with the response that you receive from us we hope that you would contact us to resolve the issue, but you also have the right to lodge a complaint with the relevant data protection authority in your jurisdiction at any time.
- To provide our Website and Services.
- To prevent risk and fraud in connection with our Website and Services.
- To provide communications, marketing, and advertising.
- To provide reporting and analytics.
- To provide troubleshooting, support services, or to answer questions.
- To test out features or additional services.
- To improve our Website and Services.
- California Residents.
This Section is only applicable to you if you are a resident of the state of California in the United States (“California Residents”) and only applies to personal information for which we are a “Business” (as defined in the California Consumer Protection Act, or “CCPA”), but does not apply to personal information we collect from you in the course of our provision of services to you where you are an employee, owner, director, officer or contractor of a company, partnership, sole proprietorship, non-profit or government agency. It applies to personal information we collect from California Residents on or through our Website or Services and through other means (such as information collected offline or in person).
- “Personal information” under California Civil Code section 1798.80: (1) sources: you (either directly or through a Third Party Provider), collected by the Website or Services, business partners, service providers, and payment processors; and (2) third parties: business partners, service providers, and payment processors.
- Identifiers: (1) sources: you (either directly or through a Third Party Provider), collected by the Website or Services, business partners, service providers, and payment processors; and (2) third parties: business partners, service providers, and payment processors.
- Protected classifications (for example, race, gender, and other demographic and socioeconomic information): (1) sources: you (either directly or through a Third Party Provider), collected by the Website or Services, business partners, and service providers; and (2) third parties: business partners, service providers, and payment processors.
- Commercial information: (1) sources: you (either directly or through a Third Party Provider), collected by the Website or Services, business partners, and service providers; and (2) third parties: business partners, service providers, and payment processors.
- Biometric information (for example, fingerprints used for verifying your identity when accessing the App): (1) sources: you (either directly or through a Third Party Provider), collected by the App, business partners, and service providers; and (2) third parties: business partners, service providers, and payment processors.
- Financial, professional, or employment-related data: (1) sources: you (either directly or through a Third Party Provider), business partners, and payment processors; and (2) third parties: business partners, service providers, and payment processors.
- Internet or other network or device activity: (1) sources: you (either directly or through a Third Party Provider), collected by the Website or Services, business partners, service providers, and payment processors; and (2) third parties: business partners, service providers, and payment processors.
- Location information: (1) sources: you (either directly or through a Third Party Provider), collected by the Website or Services, business partners, and service providers; and (2) third parties: business partners, service providers, and payment processors.
- Sensory information: (1) sources: you (either directly or through a Third Party Provider), business partners, and service providers; and (2) third parties: business partners, service providers, and payment processors.
- Other information that identifies or can be reasonably associated with you by inference or otherwise: (1) sources: you (either directly or through a Third Party Provider), collected by the Website or Services, business partners, service providers, and payment processors; and (2) third parties: business partners, service providers, and payment processors.
Each Category is collected for the following business purposes: (i) providing the Website or Services (including maintaining your Account, processing and fulfilling orders and administering surveys and contests); (ii) providing customer support; (iii) operating the Website and Services (including without limitation managing third party relationships and enabling usage of our service providers); (iv) communicating with you; (v) customizing the Website and Services; (vi) securing and protecting the Website and Services (including without limitation auditing the Website and Services, bug and fraud detection, debugging and repair of errors and the detection, protection, and prosecution of security incidents or illegal activity); (vii) enforcing our terms and policies; (viii) complying with law; (ix) verifying your identity; and (x) other business purposes about which we may notify you from time to time.
Each Category is collected for uses that advance our commercial or economic interests such as: (i) promoting surveys and contests; (ii) promoting and advertising the Website and Services; (iii) customizing the Website and Services; (iv) improving the Website and Services; (v) communicating with you about relevant offers from third parties; and (vi) other commercial purposes about which we may notify you from time to time.
- Your requests. Subject to certain exceptions and restrictions, the CCPA provides California Residents the right to submit requests to a business which has collected their personal information: (i) to provide them with access to the specific pieces and categories of personal information collected by the business about such California Resident, the categories of sources for such information, the business or commercial purposes for collecting such information (including any sale of personal information), and the categories of third parties with which such information was shared; and (ii) to delete such personal information (each, a “California Request”). We need certain types of information so that we can provide our Services to you. If you ask us to delete some or all of your information, you may no longer be able to access or use the Services. If you are a California Resident, please follow the instructions in the “Your rights and choices” section above to submit California Requests and please make sure you note that you are a California Resident when you do so. California Residents may designate an authorized agent to make California Requests on their behalf. In order to designate an authorized agent to make a California Request on your behalf, you must provide a valid power of attorney, the requester’s valid government issued identification, and the authorized agent’s valid government issued identification.
- We do not discriminate against you. You also have the right to not be discriminated against (as provided for in applicable law) for exercising certain of your rights. We do not discriminate against California Residents for exercising their rights.
- Australian Residents and anonymity and pseudonymity.
Australian residents have certain rights under the Australian Privacy Principles (“APPs”), which apply to any organization that is covered by the Federal Privacy Act 1988 (Cth). This Section applies to you if you are an Australian resident and under the circumstances the APPs and Federal Privacy Act cover our dealings with you. Where it is lawful and practicable to do so, we will give you the option of dealing with us anonymously or to use pseudonym (alias). For example, you can anonymously (or through use of a pseudonym) leave us feedback on our Website or write to us. It will not always be possible for us to deal with you anonymously or by pseudonym and it will depend on the nature of the dealing between us. In other cases, it will be impracticable for us to deal with you unless we have identified you.
- Please use caution when posting on the public areas or features of our Website and Services.
You may be able to post or make public communications on certain areas of our Website or Services, such as comments and questions fields, discussion forums, in-App communication functions, and other public discussion mechanisms. These kinds of communications are made at your own risk. Although we may monitor or even control these types of public posts, we are under no obligation to do so. We also cannot control the actions of other users of the Website or App, including how they will use your public posts and any personal information you include in them. We cannot and do not guarantee that unauthorized persons will not view your public posts or respect your privacy.
- Where we may store, process, or share your information.
We are based out of Canada, but we may process, store, and transfer personal information in Canada or elsewhere. For example, we could use third-party service providers, such as managed hosting providers, credit card processors, customer relationship management (CRM) systems, and technology partners to provide the necessary software, networking, infrastructure and other services that we use to operate the Website and Services. We may also store our data with a trusted service provider who is in the business of providing data storage and processing services. Examples are those who store and process our email and mobile application data. These services commonly involve diverse geographic locations which change from time to time for reasons which include data protection and processing efficiency. Where these services are used by us, it is not always practical for us to notify you of which country your personal information may be located in. These third-party providers may process or store personal information on servers outside of Canada or the region in which you reside.
We may also share personal information and data in diverse geographic regions when we share information between our group of companies and divisions. For example, we are a Canadian business, but we operate in the United States, Australia, and New Zealand and information may be shared between these regions as we provide our Services and operate our business.
It is our policy to require our overseas sharing of personal information to be done in a way which requires observance of strict privacy and security standards, both during transit and at the overseas destination. However, locations (including those other than Canada) may have different privacy laws, which may be more or less protective. If we move personal information to a location other than the location in which you are located, the governments, courts, law enforcement, or regulatory agencies of that country may have access to your personal information through their laws.
- How do we keep your personal information secure?
We follow industry standards on information security management to safeguard sensitive information, such as financial information, intellectual property, and any other personal information entrusted to us. Our information security systems apply to people, processes, and information technology systems on a risk management basis. No method of transmission over the Internet, or method of electronic storage, is completely secure. Therefore, we cannot guarantee the absolute security of your personal information.
- How long do we keep your personal information?
In general, we keep your personal information throughout your relationship with us. Once you terminate your relationship with us, we will continue to store archived copies of your personal information for legitimate business purposes, like defending a contractual claim or for audit purposes and to comply with the law. We will continue to store anonymous or anonymized information, such as website visits, without identifiers, in order to improve our Website and Services.
- Automated decision-making and your personal information.
We use several machine learning algorithms and forms of automated decision-making. For example, we use automated decision-making to prevent risk and fraud, to personalize your experience and make it more efficient, and to determine eligibility for certain services or features we offer on our Website and Services. We may also use such technologies to improve the Website and Services and how we deliver them to you.
- Children and privacy.
Our Website and its features and the Services are not meant for children under 13 years of age. If you are under 13 years old, please do not give us your personal information. If you are the parent or guardian of someone under 13 years of age, please do not give us personal information of that person.
- How to contact us about privacy questions.
If you wish to complain about a breach of the privacy rules that bind us, you may contact our Privacy Officer. We may ask you to put your complaint in writing and to provide details about it. We may discuss your complaint with our personnel and our service providers and others as appropriate. Our Privacy Officer will investigate the matter and attempt to resolve it in a timely way and inform you in writing about the outcome of the investigation.
If our Privacy Officer does not resolve your complaint to your satisfaction and no other complaint resolution procedures are agreed or required by law, our Privacy Officer will inform you that your complaint may be referred to the Privacy Commissioner or other similar governmental authority applicable to your region for further investigation and will provide you with the Commissioner’s (or other authority) contact details.