Last Updated: 2021-10-04
Personal Information and Consent
Personal information means information about an identifiable individual (“personal information ”), and does not include information that cannot be attributed to an identifiable individual, such as information of an aggregate or anonymous nature (collectively, “ non-personal information”).
We may rely on your implied consent in certain circumstances, after taking into account factors such as the sensitivity of the personal information and your reasonable expectations.
We will limit the collection, use, and disclosure of your personal information to only that which is necessary for the purposes identified, unless you have otherwise consented, or when such collection, use, and/or disclosure is permitted or required by law.
You can always refuse to provide your personal information, except that it may prevent you from using our Services or receiving responses to your inquiries or other information of interest.
How We Collect Personal Information
We collect two basic types of information from you when you provide it to us or when you use or interact with our Services: personal information and non-personal information.
We may collect various types of personal information from you, such as your:
We need to collect personal information from you in order to provide you with our Services and to improve your experience using our Services. We will only collect, use, and disclose the personal information that we need in order to provide you with our Services.
You may provide us with personal information in several ways, including, for example, when you:
Our Services are not for children or persons under the age of majority in the jurisdiction in which they reside. We do not knowingly collect personal information from children or persons under the age of majority in the jurisdiction in which they reside. These individuals should not attempt to use our Services or provide us with any personal information. If you think we have received personal information from children or persons under the age of majority in the jurisdiction in which they reside, please contact us immediately.
When you access our website, we (or our third party service providers) may place small data files (i.e. cookies, pixel tags, or similar technologies) on your computer or other device. These are small files that are stored on your computer browser or device when you visit certain online pages, images on web pages that track user activity on the website, or similar. We use these technologies to collect certain information in order to better your online experience and assist us with provision of the Services.
The help section of your browser or a browser add-on may provide instructions on deleting or disabling these technologies. You can delete or disable these technologies if your browser or browser add-on permits; however, if you delete or decline these technologies, some of our Services may not function properly.
Our Services do not currently change the way they operate upon detection of a “do not track” or similar signal.
We may also collect personal information from other sources (such as our third party service providers) or from our offline interactions with you to, among other things, enable us to verify or update information contained in our records and to better customize the Services for you.
Our Services may, from time to time, contain links to and from social media platforms. You may choose to connect to us through a social media platform, such as Facebook or Twitter, and when you do, we may collect additional information from you (including personal information) through the social media platform, such as your screen name, profile picture, contact information, contact list, and the profile pictures of your contacts. Please be advised that social media platforms may also collect personal information from you. When you click on a social plug-in, such as Facebook’s “like” button or Twitter’s “tweet” button, that particular social network’s plug-in will be activated and your browser will directly connect to that provider’s servers.
We do not have control over the collection, use and disclosure practices of social media platforms and encourage you to review their privacy policies and practices, including their data security practices, before using these social media platforms.
How We Use the Personal Information We Collect
We may use your personal information to:
We may use non-personal information for any legitimate business purpose, including to maintain and improve our Services.
How We Disclose Personal Information
We may disclose personal information:
We disclose non-personal information to third parties as reasonably necessary to meet our business needs. We do not disclose your personal information to third parties for their own direct marketing purposes without your consent.
How We Protect and Store Personal Information
We exercise great care in protecting your personal information and ensuring its security and confidentiality. We store personal information that we have collected in secure operating environments, and we utilize security protocols such as physical access controls, firewalls and data encryption.
All of our service providers are contractually obligated to employ appropriate data security measures with respect to your personal information and to collect/use/disclose/retain it only within the scope required for the provision of our Services. The service providers we contract with will use your personal information only if required to perform their respective services. These include, for example, IT service providers that we retain to operate and safeguard our IT system that stores your personal information.
We try our best to safeguard personal information once we receive it, but please understand that no transmission of data over the Internet or any other public network can be guaranteed to be completely secure. If you suspect an unauthorized use or security breach of your personal information, please contact us as soon as possible.
How You Can Access and Update Your Personal Information
Upon your reasonable written request, we will provide you, not later than thirty (30) days from our receipt of your request, or such additional time as required by law, with access to or information about your personal information (if any) under our custody or control, and the names of persons to whom, and any circumstances in which, your personal information has been and is being disclosed by us. You must provide sufficient information in your request to allow us to verify your identity and identify the information you are seeking.
If you request a copy of your personal information and the personal information can reasonably be reproduced, we will provide you with a copy of the personal information, or, if applicable, we will give you reasons for any delay in providing a copy of the requested personal information. All requests may be subject to minimal costs, in accordance with applicable privacy legislation.
We reserve all rights not to disclose personal information, in whole or in part, in certain circumstances permitted or required by law, including but not limited to where:
If access to your personal information is refused, in whole or in part, we will provide you with the reasons for the refusal, the provision of applicable privacy legislation on which the refusal is based, and the contact information of the Privacy Officer who can answer your questions about the refusal, and will inform you that you may ask for a review of the refusal in accordance with applicable privacy legislation.
To submit a request to access your personal information or designate an authorized agent to make a request to access your personal information, please contact us. Our security procedures mean that we may request proof of identity before we disclose your personal information to you.
Updates or Deletion
The accuracy of the information we have about you is very important. To submit a request that we update your personal information, please contact us.
On your request, we will make every reasonable effort to either correct outdated personal information, or errors or omissions in your personal information, or delete your personal information where that personal information is in our custody or control. Such request must be in writing, signed by you, and include sufficient detail to enable us to identify any personal information in our custody or control in relation to the request.
We will, as soon as reasonably practical and not later than thirty (30) days from our receipt of your request, or within such additional time as permitted or required by law, either correct the personal information and, if applicable and reasonable to do so, send correction notifications to any third party to whom we disclosed the incorrect personal information, or decide not to correct the personal information, but we will annotate the personal information under our control to indicate that a correction was requested but not made.
We will inform you of the action that we have taken in response to your request for correction, the contact information of the Privacy Officer who can answer your questions about your request for correction, and that you may ask for a review of the action taken in accordance with applicable privacy legislation.
How You Can Contact Us About Your Privacy