Suite 1600 - 2300 Yonge Street  |  Toronto, ON M4P 1E4
Tel: 416-876-4281    |   info@retainify.com

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©Retainify Technology Inc. 2018, All Rights Reserved.

 

PRIVACY POLICY

 

Last Updated: August 15, 2018

 

Introduction

 

At Retainify Technology Inc. (“Retainify”, “We” or “Us” and terms of similar meaning), we are committed to your privacy.  This means we do not transfer, distribute, disclose, rent or sell any of your personal information to third parties except as provided for in this policy (the “Privacy Policy”) or as specifically consented by you.

 

Retainify has developed policies and procedures consistent with the Personal Information Protection and Electronic Documents Act (“PIPEDA”), and other relevant privacy laws.  By accepting this Privacy Policy in registration or by visiting and using our Retainify Platform (the “Site”) and/or utilizing the services through the Site (the “Services”), you expressly consent to our collection, use and disclosure of your personal information in accordance with this Privacy Policy.  This Privacy Policy is incorporated into and subject to our Terms of Service.

 

Scope

 

This Privacy Policy applies to all personal information (“Personal Information”) collected, used or disclosed by Retainify from identifiable individuals. More specifically, we collect personal information from the following categories of people:

 

  • Customers: you hold an account with Retainify and you either directly create surveys, forms, applications, or questionnaires or you are collaborating on, commenting on, or reviewing surveys, forms, applications, or questionnaires within an account.

  • Respondents: you are an employee of a customer or a user of a customer’s products or services  (collectively a “User”) and are taking surveys sent to you by Retainify on behalf of our customer.

  • Site Visitor: you are visiting our Site.

 

Accountability

 

Retainify is responsible for the Personal Information under our possession and control.  We have designated a Privacy Officer to be responsible for our compliance with this Privacy Policy and privacy legislation.

 

Information We Collect

 

a. Personal Information

 

Personal information is any information recorded in any form that identifies or can identify an individual and includes any information provided to us by you in using our Site or Services.  Personal Information that we collect includes:

 

  • Contact Information (for example an email address): You might provide us with your contact information, whether through use of our Services, a form on our Site, an interaction with our sales or customer support team, or a response to one of Retainify’s own surveys.

  • Usage information: We collect usage information about you whenever you interact with our Sites and Services. This includes which webpages you visit, what you click on, when you perform those actions, and your language preference.

  • Device and browser data: We collect information from the device and application you use to access our services. Device data mainly means your IP address, operating system version, device type, system and performance information, and browser type. If you are on a mobile device we also collect the UUID for that device.

  • Information from page tags: We use third party tracking services that employ cookies and page tags to collect data about visitors to our websites. This data includes usage and User statistics. Emails sent by Retainify or by Users through our services include page tags that allow the sender to collect information about who opened those emails and clicked on links in them. We provide more information on cookies below.

  • Log Data: our web servers keep log files that record data each time a device accesses those servers. The log files contain data about the nature of each access, including originating IP addresses, internet service providers, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system versions, device type and timestamps.

  • Information from third parties and integration partners: we collect your personal information or data from third parties if you give permission to those third parties to share your information with us or where you have made that information publically available online.

 

If you are Customer we will also collect:

 

Account Information

 

  • Registration information:  You need a Retainify account before you can use the Services. When you register for an account, we collect your first and last name, username, password and email address.

  • Billing information: if you make a payment to Retainify, we require you to provide your billing details, a name, address, email address and financial information corresponding to your selected method of payment (e.g. a credit card number and expiration date or a bank account number). If you provide a billing address, we will regard that as the location of the account holder to determine which Retainify entity with whom you contract.

  • Account settings: You can set various preferences and personal details on our customer setting pages. For example, your default language, time zone and communication preferences (e.g. opting in or out of receiving marketing communications from Retainify).

  • User information: You may provide us with certain information about your Users whom you wish to take the survey, such as hire dates, birth dates, job title, etc.

 

Use of some of our services will also result in us collecting the following data on your behalf:

 

  • Address book information: We allow you to import email addresses into our platform, so you can easily invite Users to take your surveys or fill in your form via email. We don’t use these email addresses for our own purposes or email them except at your direction.

  • Survey/form/application data: We store your survey/form/application data (questions and responses) for you and provide analysis tools for you to use with respect to this data.

 

b. Non-Personally Identifiable Information

 

Personal information does not include information that is aggregated or anonymized in such a manner that it cannot be connected to you or any User.  This may include grades and participation rates aggregated among many Users.  Such information by itself or together cannot be tracked to a specific individual’s personally identifiable information.

 

How do we use Personal Information?

 

Retainify collects Personal Information for the following purposes:

 

  • to provide Services to you and your Users;

  • to establish and maintain responsible commercial relations and to communicate with you in order to provide service. This includes, but is not limited to, communications relating to billing, payments, advertising, promotion and account verification;

  • to respond to any correspondence you may direct to us;

  • to understand, research, and improve our Services, including understanding survey data and user feedback;

  • customer needs and preferences;

  • to direct advertisements to you about our company and our products and services that may be of interest to you;

  • to enforce our Terms of Service and legal agreements;

  • to provide you with system or administrative messages;

  • to meet legal and regulatory requirements; and

  • for any other reasonable purposes for which you may have provided your express consent or in which your consent can be reasonably implied.

 

How do we use Non-Personally Identifiable Information?

 

In an ongoing effort to better understand and serve the users of our Services and improve our Service and user functionality, we conduct research on our customer and User demographics,  and behavior based on Personal Information and other information that we have collected.  This research may be used by Retainify to analyze and improve our services to our customers, benchmarking for our customers, prepare Whitepapers, and to direct advertising to our customers.  This research will be compiled and analyzed on an aggregate basis and this aggregate does not identify any individual and therefore is considered and treated as Non-Personally Identifiable Information under this Privacy Policy. 

 

Consent

 

We respect your privacy and, unless otherwise required by law, we will not collect, use or disclose your Personal Information without your prior consent. Your consent may be expressed or implied. You may expressly give your consent in writing, verbally or through any electronic means.  In certain circumstances, your consent may be implied by your actions.  For example, providing us Personal Information to register for our Services is implied consent to use such information to provide you the associated services.

 

Where appropriate, Retainify will generally seek consent for the use or disclosure of the information at the time of collection. In certain circumstances, consent with respect to use or disclosure may be sought after the information has been collected but before use (for example, when Retainify wants to use information for a purpose other than those identified above).  In obtaining consent, Retainify will use reasonable efforts to ensure that a customer is advised of the identified purposes for which Personal Information collected will be used or disclosed.

 

The form of consent sought by Retainify may vary, depending upon the circumstances and type of information disclosed. In determining the appropriate form of consent, Retainify shall take into account the sensitivity of the Personal Information and the reasonable expectations of our customers and Users.  Retainify will seek express consent when the information is likely to be considered sensitive. Implied consent will generally be appropriate where the information is less sensitive.

 

You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice, however, withdrawing consent may result in our inability to provide you with certain Services. In order to withdraw consent, you must provide notice to Retainify in writing.

 

Limiting Use, Disclosure and Retention

 

Unless required by law, or in connection with a business transaction, Retainify shall not use or disclose or transfer Personal Information for any purpose other than those described above without first identifying and documenting the new purpose and obtaining your consent, where such consent may not reasonably be implied.

 

As noted above, Retainify does not disclose your Personal Information to third parties.  Notwithstanding, your Personal Information may be transferred to third party suppliers, contractors and agents (“Affiliates”) who are contracted by Retainify to assist it in providing and developing products and services, for example customer service and user support, and payment processing. Such Affiliates will only use your Personal Information for the purposes identified in this Privacy Policy. Such Affiliates may be located outside of Canada, including in the United States, and your Personal Information may be collected, used, disclosed, stored and processed in such jurisdictions for the purposes described in this Privacy Policy.  Retainify takes reasonable contractual or other measures to protect your Personal Information while processed or handled by such Affiliates. If your Personal Information is located outside Canada it will be subject to legal requirements in those foreign countries applicable to our service providers, for example, lawful requirements to disclose Personal Information to government authorities in those countries.

 

In the event your Personal Information is disclosed to a third party pursuant to a business transaction (including a potential sale or financing), Retainify will ensure that it has entered into an agreement under which the collection, use and disclosure of the information is related to those purposes that relate to the transaction.

 

Subject to the foregoing, only Retainify’s and our Affiliates’ employees with a business need to know, or whose duties reasonably so require, are granted access to Personal Information about our Users.   All such employees will be required as a condition of employment to contractually respect the confidentiality of your Personal Information.

 

Retainify will retain Personal Information for only as long as required to fulfill the identified purposes or as required by law. Personal Information that is no longer required to fulfill the identified purposes will be destroyed, erased or made anonymous according to the guidelines and procedures established by Retainify.

 

Using the Site & Cookies

 

In order to improve the Site, we may use small files commonly known as “cookies”. A cookie is a small amount of data, which often includes a unique identifier that is sent to your computer or mobile phone (your “device”) from the Site and is stored on your device’s browser or hard drive.  Cookies are used in analyzing trends, administering the site, tracking users’ movements around the site and to gather demographic information about our user base as a whole. We may generate reports based on the use of these technologies an aggregated basis

The cookies we use on the Site won't collect personally identifiable information about you and we won't disclose information stored in cookies that we place on your device to third parties.  We use cookies to remember users’ settings, store login addresses, authenticate users, run website experiments, and store analytics data, such as browser, device type and operating system.

 

Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our site, but your ability to use some features or areas of our site may be limited.

 

You can find more information about how to do manage cookies for all the commonly used internet browsers by visiting www.allaboutcookies.org. This website will also explain how you can delete cookies which are already stored on your device.

 

Cookies from third parties 

 

We use Google Analytics, a web analytics service provided by Google Inc. ("Google") on the Site. Google Analytics uses "cookies", which are text files placed on your computer, to help the Sites analyse how users use the Site. The information generated by the cookie about your use of the Sites (including your IP address) will be transmitted to and stored by Google on servers in the United States.  Google will use this information for the purpose of evaluating your use of the Site, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage.  Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google.  You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of the Sites.  By using the Site, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

 

We may use additional third party and such parties will have their own privacy policies describing how they use information that they collect.

 

How can I Access my Personal Information?

 

Upon request, Retainify will provide information to a User regarding the existence, use and disclosure of his or her Personal Information.  Retainify will respond to an application for individual access to Personal Information within a reasonable time and at minimal or no cost to the individual. A User may challenge the accuracy and completeness of the information and have it amended as appropriate.

 

NOTE: In certain circumstances, Retainify may not be able to provide access to all the Personal Information it holds about a User.  Exceptions may include information that is prohibitively costly to provide, information that contains references to other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons, or information that is subject to solicitor-client or litigation privilege. Retainify will provide the reasons for denying access upon request.

 

Safeguards

 

We take administrative, technical and physical measures to safeguard your personal information against unauthorized access, unauthorized disclosure, theft and misuse. This includes limiting access of employees to, and the use of, your personal information through the use of passwords and graduated levels of clearance. We do not publish all of our security measures online because this may reduce their effectiveness. We take physical precautions to ensure that the computer servers on which your personal information is stored and archived are secure and in a controlled environment with limited access. We educate our employees with respect to their obligations to protect your personal information.

 

Although we take precautions against possible breaches of our security systems, no company can fully eliminate the risks of unauthorized access to your personal information and no website is completely secure. We cannot guarantee that unauthorized access, hacking, data loss or breaches of our security systems will never occur. Accordingly, you should not transmit personal information to us using our website if you consider that information to be sensitive.

 

Challenging Compliance

 

An individual will be able to address a challenge concerning compliance with this Privacy Policy to Retainify's Privacy Officer.

 

Retainify will maintain procedures for addressing and responding to all inquiries or complaints from Users about Retainify's handling of Personal Information. Retainify shall investigate all complaints. All inquiries or complaints involving Retainify's handling of Personal Information or compliance with this policy or with PIPEDA shall be directed to Retainify's Privacy Officer.

 

The Privacy Officer will respond to all such inquiries or complaints within 14 business days of receipt.  The Privacy Officer will make reasonable efforts to resolve all such complaints within 30 days of receipt of the initial complaint. If Retainify finds a complaint to be justified, it will take appropriate measures, including, if necessary, amending its policies and procedures.

 

For more information, please contact our Privacy Office as follows:

 

E-mail: info@retainify.com

 

Mail:     Suite 1600 - 2300 Yonge Street

              Toronto, ON

              Canada

              M4P 1E4

 

Children and Minors

 

Our Site and the Services offered on our Site are not directed to children under the age of 13 years.  We will not knowingly collect Personal Information about a child under the age of 13.

 

General

 

Retainify reserves the right to modify and amend this privacy policy from time to time in its sole discretion without prior notice. Any such amendment(s) will be posted on our Site and will be effective as of the date of posting.