- What information we collect and why we collect it.
- How we use that information and when we disclose it.
- How to access and update your personal information.
Your privacy matters to us so please take the time to familiarize yourself with our policies, and if you have any questions please contact us at [email protected]
IMPORTANT INFORMATION AND WHO WE ARE
Our full details are:
Email address: [email protected]
Postal address: 150 King St W, Toronto, ON, Canada, M5H 1J9
If you are based in the European Union, you also have the right to make a complaint at any time to your local supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the regulator so please contact us at [email protected] in the first instance.
This version was last updated on August 25, 2019.
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.
This Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share information about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy notice of every website you visit.
THE INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT
Personal data, or personal information, means any information relating to an identifiable person who can be directly or indirectly identified. It does not include data which cannot be related to an identifiable person (anonymous data).
We may collect, use, store and transfer different kinds of personal information about you which includes:
- Contact Data includes telephone number. We collect this information to register a new user, provide ability to vote and send you notifications about relevant polls in your city and other updates.
- Location Data includes data based on your location as recorded through the App. We collect this information to ensure you are properly matched to the local polls and surveys.
- Technical Data includes internet protocol (IP) address, your mobile device’s unique ID number, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Website. We collect this information to administer and protect our business and this Website and Mobile App (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
- Usage Data includes information about how you use our Website, app(s) and Services, such as the buttons, controls, products and ads you click on, pages of our application or Website that you visit, the time spent on those pages, your search queries, the dates and times of your visits, but also about the webpage you were visiting before you came to our Website app(s) and the webpage, app(s) you go to next. We collect this information to use data analytics to improve our website, services,customer relationships and experiences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal information but is not considered personal information in law as this information does not directly or indirectly reveal your identity.
HOW WE USE YOUR PERSONAL INFORMATION
We will not use your personal information for purposes other than those purposes we have disclosed to you, without your permission. Most commonly, we will use your personal data in the following circumstances:
- Where you have consented to that use as described in this policy (which consent will be signified by your continued use of the Services);
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; or
- Where we need to comply with a legal or regulatory obligation.
You can ask us to stop sending you marketing messages at any time by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal information provided to us as a result of a service purchase, service experience or other transactions. If you choose to limit the use of your personal information, certain features or Services may not be available to you.
Visiting our Website
When you visit our website, the hosting provider of our website, Amazon Web Services (AWS) automatically collects and stores various information in so-called server log files that your browser transmits to us. The information/data mentioned is neither assigned to specific persons nor linked to data from other sources. The following technical data will be recorded by us, as usual with every connection with a web server, without your intervention, and stored by us until automatic deletion after no later than six months. The collection and processing of this technical data is for the purpose of enabling the use of our website, continuously ensuring system security and stability, optimising our website, and for internal statistical purposes. This is our legitimate interest in the processing of data in the sense of Art. 6 Par. 1 lit. f GDPR. Furthermore, the IP addresses will be evaluated, together with other data, in case of attacks on the network infrastructure or other unauthorised use or misuse of the website, for the purpose of intelligence and protection, and if appropriate, used in criminal proceedings for identification and civil and criminal proceedings against the relevant users. This is our legitimate interest in the processing of data in the sense of Art. 6 Par. 1 lit. f GDPR.
Use of Website Cookies
You may, at any time, prevent the setting of cookies through our Website by means of a corresponding setting of the Internet browser used, and may thus permanently deny the setting of cookies. Furthermore, previously set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, it may not be possible to use all the functions of our Website.
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies), you may not be able to access all or parts of our sites.
- Strictly necessary cookies. These are cookies that are required for the operation of our Website. They include, for example, cookies that enable you to log into secure areas of our Website or make use of e-commerce payment processing services.
- Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our Website when they are using it. This helps us to improve the way our Website work, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies. These cookies are used to recognise you when you return to our Website. They enable us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
- Targeting cookies. These cookies record your visit to our Website, the pages you have visited and the links you have followed.
You can find more information about the individual cookies we use and the purposes for which we use them in the table below:
|Google Analytics||_ga||Used to distinguish users. Enables us to identify which pages are popular, estimate our audience size and usage pattern, and better understand how the web site is used.|
|Google Analytics||_gid||Used to distinguish users. Enables us to identify which pages are popular, estimate our audience size and usage pattern, and better understand how the web site is used.|
|Google Analytics||_gat||Used to throttle request rate. This cookie does not store any user information. It is used by Google limit the number of requests that have to be made to doubleclick.net (which will be zero in our case because we do not use any ads on our site).|
This Website also uses Google Analytics, a web analysis service provided by Google Inc. ("Google"). Google Inc. is an enterprise of the holding company Alphabet Inc., domiciled in the USA. The information generated by the cookie about your use of the Website (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 website, compiling reports on Website activity and providing other services relating to Website activity and internet usage. Google may also transfer this information to third parties if this is required by law or if third parties process this data on behalf of Google.
Generally, before the data is transmitted to the provider, the IP address will be abbreviated by activating IP anonymization (anonymizeIP) on this website, within the member states of the European Union or in other contracting states of the agreement on the European Economic Area. Only in exceptional cases will the full IP address be sent to a Google server in the USA and abbreviated there. In these cases, we provide contractual guarantees to ensure that Google Inc. maintains a sufficient level of data protection. According to Google Inc., under no circumstances will the IP address be associated with any other user-related data. More information about the web analytics service used is available at the Website of Google Analytics: https://www.google.ch/policies/privacy/partners
In addition to the data listed in section 3.1, we may receive the following information of Google Analytics:
- Navigation path
- Length of stay on the website
- Returning or new user
- End device
We do not use the information and personal data collected by Google Analytics to identify individuals unless we become aware of specific indications of illegal use.
DISCLOSURES OF YOUR PERSONAL INFORMATION
We may have to share your personal information with the parties set out below for the purposes set out above:
- Service providers who provide IT and system administration services.
- Professional advisers including lawyers, bankers, auditors and insurers based in Canada and the United States who provide consultancy, banking, legal, insurance and accounting services.
- Regulators and other government authorities [acting as processors or joint controllers] based in Canada, the United States and in the EEA who require reporting of processing activities in certain circumstances.
We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.
Please note that neither the Website nor the Service is intended for children under 18 years of age. No one under age 18 may provide any information to or on this Website or through our Services. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on this Website or on or through any of its features, use any of the interactive or public comment features of this Website or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us.
Our technology allows us to record the votes anonymously without tying them to personal identity (after validation of your eligibility to vote based on location). Neither we nor any of our Poll Requesters can know how you voted in any poll through the Services.
We share your personal information within our company. This will involve, if you are based in the European Union, transferring your data outside the European Economic Area (EEA). If you are based in the European Union, whenever we transfer your personal information out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring appropriate safeguards are implemented.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax and other legally required purposes.
In some circumstances you can ask us to delete your information: see Request erasure below for further information.
In some circumstances we may anonymize your personal information (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal information. You may have the right to:
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information in the following scenarios: (a) if you want us to establish the information’s accuracy; (b) where our use of the information is unlawful but you do not want us to erase it; (c) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal information to you or to a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us at [email protected]
Last updated: August 25, 2019