Last updated on: January 8, 2019
1. Your Personal and Non-Personal Information
There are two basic types of data that we collect on our Sites: PII and non-personal information.
PII is data that that can be used to identify or contact a single person or entity, such as your email address or data about activities that are directly linked to you.
Non-personal information is data we collect in a form that does not, on its own, permit direct association with any specific individual, which may include demographic data. Data on how you use our Sites may be collected and combined with data about how others use our Sites, but no PII will be included in the resulting data set. This type of data helps us understand trends in our users’ needs. We may collect, use, transfer, and disclose non-personal information for any purpose, such as to better understand and improve our Sites, and for advertising and marketing purposes.
We may receive certain types of data automatically whenever you interact with us. For example, when you use our Sites our systems may automatically collect your IP address and the type of browser or operating system you use.
We may also collect standard access data, such as the time, date and usage of Site access. We use such data to help us understand how our visitors use our Sites including visitor count and aggregated statistics about Site usage.
We commonly collect, use, and process basic contact data, biographical data, and payment data. You may provide us your PII when you email us, contact us via our Sites or social media accounts, communicate with us via telephone or text messaging, register for our Services, or open a support ticket.
When you register with us, we may collect a variety of PII, including your name, date of birth, mailing address, phone number, email address, contact preferences, and credit card and other payment information. We also collect any other information you provide to us, such as academic and employment information. We use this information to communicate with you, including by email and/or SMS or text messages, about our Services and to respond to your questions, to offer you advice through our Services, or to provide you with additional content or information that might be relevant or interesting to you.
Users can also post materials and other information through their use of our community forums. You will determine what materials and information you post, and because those postings will be viewable by other users and by the public, you should have no expectation of privacy with respect to such postings. By posting or submitting your content to our Sites and/or Services, you represent and warrant that you own or otherwise control all of the rights thereto, and that use of your content on the Sites and/or Services will not infringe or violate the rights of any third party or any applicable law.
We have many email newsletters and marketing preferences for you to choose from and realize your preferences may change over time. To change your e-mail newsletter preferences, or to unsubscribe, please click on the relevant link in our emails and follow the directions.
Cookies and Other Technologies
Special rules for children
2. USE OF PII
All PII and content submitted by you is stored in our database and may be archived elsewhere. Our system administrators and support personnel will have access to PII that we process. In general, we use PII internally to serve our users and enable them to take maximum advantage of our Services. For example, PII is used to resolve technical support cases, to conduct marketing analysis, to create an individual profile and provide personalized services, to provide services or complete transactions you have requested, to anticipate and resolve problems with our Services, and to create and inform you of new products and services that better meet your needs. We may communicate with you at any of the points of contact that you provide to us for any of the aforementioned purposes.
We do not rent, sell, or share PII about you with other people or non-affiliated companies except (i) as necessary to complete a transaction you have requested, (ii) as necessary to perform internal analyses, technical support, and other business functions, (iii) as part of a business transfer, or (iv) when required by law or permitted in order to protect our rights, property, or safety.
In accordance with our Terms and Conditions, Recordings may be used by us for our internal purposes, for development of new products and services, and for any purpose expressly permitted hereunder. Any PII of yours that may be incorporated into or forms part of any Recordings will not be incorporated into any products or services offered or made available by us.
Unless you choose to do so, we will not disclose your PII to third parties for their direct marketing purposes. With your consent, we may disclose your PII to third parties so that they may provide you with products and services that you have requested.
Vendors or service providers we may disclose PII to include:
- Independent contractors who supply the Services
- Cloud-based hosting providers
- Cloud-based CRM solutions
- Videoconferencing tools
- Marketing automation and data enrichment platforms
- Customer relationship management platforms
- Customer support and community platforms
- Social media platforms
- Human resource information service platforms
- Accounting and finance platforms
- User analytics platforms
- Consulting firms
We may also disclose the information that we collect about you in the following ways:
- We may disclose your information to another entity as part of a merger or acquisition, creation of a separate business to provide the Services or fulfill products, sale or pledge of company assets, as well as in the event of an insolvency, bankruptcy, or receivership.
- We may disclose aggregate or de-identified information about our users for marketing, advertising, research or similar purposes.
We retain personal data only for as long as necessary for a specified purpose or legal requirement wherever technically and operationally feasible and in accordance with any applicable regulations.
3. THIRD-PARTY SITES
Co-branded websites and links to third party websites may be accessible through our Sites. Third parties may have their own privacy policies and data collection practices that differ from ours and we are not responsible for the content or the data collection practices of those sites. We are not responsible and assume no liability for the information practices of such third-party websites, and we encourage you to review and understand their privacy practices before deciding to provide them with data.
4. NETWORK AND DATA SECURITY
We have taken steps to help protect the information we collect from loss, misuse, unauthorized access, disclosure, alteration, and destruction. However, no data security measures can guarantee 100% security. Users should take steps to protect against unauthorized access to their accounts by, among other things, choosing a robust password that nobody else knows or can easily guess and keeping their log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on an account because of unauthorized password activity.
In compliance with applicable law, we will notify governmental authorities of any data security breach of which we become aware as and when required to do so in accordance with applicable laws, and, if it involves a high risk to your personal information, we will notify you as well.
5. ACCESS AND CONTROL OF PII
Please note that data that you may wish to remove may remain in our databases or backups because it is not always possible to completely remove or delete data from those locations.
6. INTERNATIONAL TRANSFER OF PII
In this Section 6, we provide information about the circumstances in which the PII of users who are resident in or subject to the European Commission’s (“EC”) General Data Protection Regulations (“GDPR”) (“EU users”) may be transferred to countries outside the European Economic Area (“EEA”).
We have offices and facilities in Canada. The EC has made an "adequacy decision" with respect to the data protection laws of Canada. Transfers to Canada will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained on the internet.
The hosting facilities for our Sites are situated in Canada and the United States. The EC has made an "adequacy decision" with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the EC a copy of which you can obtain on the internet.
Our service providers are situated in Canada and the United States. The EC has made an "adequacy decision" with respect to the data protection laws of each of these countries. Transfers to Canada and the United States will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the EC, a copy of which can be obtained on the internet.
You acknowledge that PII that you submit for publication through our Sites or Services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
7. OTHER SPECIFIC USER TERMS
(i) EU users
In this section we have summarized the rights that EU users have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
You have the right to confirmation as to whether or not we process your PII and, where we do, access to the PII, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your PII. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can access your PII by contacting us.
You have the right to have any inaccurate PII about you rectified and, taking into account the purposes of the processing, to have any incomplete PII about you completed.
In some circumstances you have the right to the erasure of your PII without undue delay. Those circumstances include: the PII is no longer necessary in relation to the purposes for which it was collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the PII has been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
In some circumstances you have the right to restrict the processing of your PII. Those circumstances are: you contest the accuracy of the PII; processing is unlawful but you oppose erasure; we no longer need the PII for the purposes of our processing, but you require the PII for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your PII. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
You have the right to object to our processing of your PII on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the PII unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
You have the right to object to our processing of your PII for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your PII for this purpose.
You have the right to object to our processing of your PII for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
To the extent that the legal basis for our processing of your PII is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your PII from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
If you consider that our processing of your PII infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
To the extent that the legal basis for our processing of your PII is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
You may exercise any of your rights in relation to your PII by written notice to us, in addition to the other methods specified in this Section 7.
(ii) California users
We do not track our customers over time and across third party websites to provide targeted advertising and therefore do not respond to Do Not Track (“DNT”) signals. However, some third party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you and may provide for you to initiate a DNT signal. Third parties that may place content embedded on our websites such as a social or community feature may set cookies on a user’s browser and/or obtain information about the fact that a web browser visited one of our Sites from a certain IP address. Third parties cannot collect any other personally identifiable information from our websites unless you provide it to them directly.
California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits users who are California residents to request and obtain from us once a year, free of charge, information about their PII that we disclosed to third parties for direct marketing purposes in the preceding calendar year. If you are a California resident and would like a copy of this notice, please send an e-mail to firstname.lastname@example.org or write to us at 4711 Yonge Street, 10th Floor, Toronto, Ontario, Canada M2N 6K8. Not all information sharing is covered by the "Shine The Light" requirements and only information on covered sharing will be included in our response. Under California law, businesses are only required to respond to a request once during any calendar year.
8. CONTACT US
If you have any questions or complaints about how we process your PII, please contact us via our contact form or using the information below.
Astroff Consultants Inc.
4711 Yonge Street, 10th Floor
Toronto, Ontario Canada M2N 6K8