Commitment to Privacy of Personal Information
This Policy may be updated from time to time to reflect developments in Privacy Analytics Incorporated practices, technology or in the law. Updates will be made available in the same way as the Policy.
This Policy only applies to the extent that PAI determines the purposes and means of the processing of personal information (i.e., is a “controller” or “business” in relation to the information). It does not apply when PAI is acting as a processor or service provider to its customers.
What Information We Collect and Maintain About You
We collect personal and other information from you directly when you provide it to us through the website. We also automatically collect certain information about you and your computer, smartphone, or other device when you use, access, or interact with the Services. We may also collect information from third parties in relation to providing you the Services.
Personal information collected through the Site. You can visit the website without submitting any information that we can use to identify you personally. However, to use certain features, such as the “Contact” and “Careers” features or sign up for our newsletter, you will be required to provide personal information. Such information could include, for example, your name, email address, organization, position, and address.
Web log data. When you use the Site, we automatically receive and record certain information from your computer (or other device) and your browser. This may include such data as your IP address and domain name, the pages you visit on the Site, information about your activity on a page, the date and time of your visit, the files that you download, the URLs from the websites you visit before and after navigating to the Site, your software and hardware attributes (including device IDs), your general geographic location (e.g., your city, state, or metropolitan region), and certain cookie information (see below). To obtain such information, we may use web logs or applications that recognize your computer (or other device) and gather information about its online activity.
Web beacons. The Site or the emails that you receive from us may use an application known as a “web beacon” (also known as a “clear gif” or “web bug”). A web beacon is an electronic file that usually consists of a single-pixel image. It can be embedded in a web page or in an email to transmit information, which could include personal information. For example, it can allow an email sender to determine whether a user has opened a particular email.
Purposes and Legal Bases for Processing Personal Information
We use the information that we collect for a variety of purposes. Our legal bases for processing your personal information are: 1) our legitimate interest in running and maintaining our business; 2) performance and fulfillment of our contracts; 3) your consent; and 4) compliance with our legal obligations. In many instances, more than one of these legal bases apply to the processing of your personal information.
Please note that we often process personal information on behalf of our customers as a data processor. In these situations, our customers determine the purposes and means of processing, as well as the relevant legal bases.
As a controller, PAI collects and uses personal information for the following purposes:
- Provide you with the Services;
- Respond to your questions or requests concerning the Services;
- Fulfill the terms of any agreement you have with us;
- Fulfill your requests for the Services or otherwise complete a transaction that you initiate;
- Send you information about the Services and other topics that are likely to be of interest to you, including newsletters, updates, or other communications, including promotional emails;
- Improve our algorithms;
- Deliver confirmations, account information, notifications, and similar operational communications;
- Improve your user experience and the quality of our products and Services;
- Comply with legal and/or regulatory requirements;
- Aggregate and deidentify information;
- Benchmark results for our customers;
- Serve advertisements;
- Analyze how visitors use the Services and various Services features, including to count and recognize visitors to the Services;
- Create new products and Services; and
- Manage our business.
PAI will identify the purposes for which the information is being collected before or at the time of collection. If information is to be used for a purpose not previously identified, PAI will identify this purpose prior to use and provide individuals with an opportunity to opt out of this activity.
With Whom and Why We Share Your Information
We share your information with other parties for a variety of purposes, as described below.
Third-party service providers. We use third-party service providers that perform services on our behalf, including web-hosting companies, mailing vendors, and analytics providers. These service providers may collect and/or use your information, including information that identifies you personally, to assist us in achieving the purposes discussed above.
We may share your information with other third parties when necessary to fulfill your requests for services; to complete a transaction that you initiate; to meet the terms of any agreement that you have with us or our partners; or to manage our business.
Legal purposes. We may use or share your information with third parties when we believe, in our sole discretion, that doing so is necessary:
- To comply with applicable law or a court order, subpoena, or other legal process;
- To investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of our terms and conditions, or situations involving threats to our property or the property or physical safety of any person or third party;
- To establish, protect, or exercise our legal rights or defend against legal claims; or
- To facilitate the financing, securitization, insuring, sale, assignment, bankruptcy, or other disposal of all or part of our business or assets.
Aggregated and de-identified information. From time to time, we may share aggregated or de-identified information about users, such as by publishing a report on trends in the usage of the Site. Such aggregated information will not identify you personally.
To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect online. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional disclosure.
By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the website or sending an e-mail to you. You may have a legal right to receive this notice in writing.
Your Privacy Choices
Depending on your jurisdiction, you may also have certain legal rights in relation to the processing of your personal information. These rights may include:
- The right to access your personal information (including a data portability request);
- The right to correct or amend any personal information we have on file about you;
- The right to delete your personal information;
- The right to limit the use of your “sensitive” personal information;
- The right to opt-out of the sale or “sharing” of your personal information;
- The right to opt-out of the use of your personal information for targeted advertising purposes;
- The right to restrict or object to the processing of your personal information (such as for direct marketing purposes);
- The right to restrict the use of your personal information for certain automated decision-making (including profiling); and
- The right to revoke your consent (to the extent applicable).
To exercise any of these rights, please use this form or contact us using the information provided below. When submitting a request by email, please provide us with your name, physical address, and the email address associated with your interactions with PAI (if different) in order for us to verify your identity. You may also designate an authorized agent to submit a request on your behalf. To designate an agent, please also send us a written and signed document by both you and the agent that authorizes the agent to act on your behalf. You may also use a power of attorney. Please note that we will still require you to provide sufficient information to allow us to reasonably verify that you are the person about whom we are receiving a request. We will respond to any request you submit in the time period required by applicable law.
Depending on your jurisdiction, you may also have the right to lodge a complaint with your supervisory authority or challenge our decision with regard to any of your data protection rights.
If you are a California resident, please review our California Privacy Notice for additional rights that may apply to you.
Display Advertising, Remarketing & Audience Data
- Third party vendors, including Google, to show our ads on sites across the Internet and remarketing with Google Analytics and other platforms to advertise online.
- Display advertising to show relevant offers to our website visitors.
- Third party vendors (including Google), first party cookies (e.g., Google Analytics cookie) and third party cookies together to inform, optimize, and serve advertisements based on someone’s past visits to our website.
- Data from Google’s Interest-based advertising or 3rd party audience data (e.g., age, gender, and interests) with Google Analytics.
Do Not Track
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online Services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
Protecting the privacy of the very young is especially important. For that reason, we do not intend to collect or maintain information from those people we know are under 13 years of age, and no part of our Services are structured to attract anyone under 13. If you learn that your child has provided us with personal information without your consent, you may contact us using the information below. If we learn that we have collected any personal information from children under 13 (and in certain jurisdictions under the age of 16), we will promptly take steps to delete such information.
The information you provide to us may be archived or stored periodically by us according to backup processes and will only be retained for as long as is required for the purposes for which it was collected, provide our products and Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.
International Users and Transfers
If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States or Canada and processing globally. By providing your information, you consent to any transfer and processing in accordance with this Policy.
This Site may contain links to third-party websites. If you use these links, you will leave the Site. We have not reviewed these third-party sites and do not control and are not responsible for any of these sites, their contents, or their privacy policies. Thus, we do not endorse or make any representations about them, or any information, software, or other products or materials found there, or any results that may be obtained from using them. If you decide to access any of the third-party sites listed on our website, you do so at your own risk.
Questions and Complaints
For further information about the information handling practices of PAI, or to make a complaint, please contact the Privacy Officer using the contact information below. PAI will investigate all complaints and will take appropriate action to address the results of the investigation.
The Privacy Officer may be contacted at:
Privacy Analytics Incorporated
251 Laurier Ave W. Suite 1000
Ottawa, ON, K1P 5J6, Canada
Phone: 613.369.4313 Extension 0