2. TABLE OF CONTENTS
3. ABOUT US
FLOGEN Technologies Inc.
or 1255 Laird Blvd, Ste 388-1, Montreal, QC, Canada, H3P 2T1.
5.INFORMATION WE COLLECT FROM YOU
In the course of your use of the Services, we obtain the following information about you as described below.
SIGNING UP FOR SERVICES; USER INFORMATION
- Information you provide prior to any registration process, such as your email when you provide it to us;
- Information that you provide during any registration process, including in connection with a co-branded offer (such as your name, company name, email address, phone number, billing address or credit card information, geographic location and industry), when you call or email us (for support or otherwise) or when you use our products or services; and
- Payment information that you provide to us (by way of our Services or otherwise) when you purchase some of our products and services, including credit card data.
USE OF SERVICES, WEBSITE VISITS AND SUPPORT
- Data relating to your online activity on our websites with respect to our Services, including the following:
We store this data we collect in a variety of places within our infrastructure, including system log files, back end databases and analytics systems.
- IP address
- browser type and version
- geographic location
- pages you view
- how you got to our Services and any links you click on to leave our Services
- when you update your information, communicate with us, or order new Services
- metadata about your use and your contacts' use of our Services and your emails you send (including clicks and opens)
- your interactions with any videos we offer
- issues you encounter requiring our support or assistance
- any device or other method of communication you use to interact with the Services
- Your telephone information when utilized in communicating with us
- Information from third party social networking sites, including information that social networking sites provide to us if you use your credentials at such social networking sites to log into some of our Services (such as your name and email address to pre-populate our sign-up form).
- The information you allow us to access varies by social networking site and depends on the level of privacy settings you have in place at the social networking site. You can control and find out more about these privacy settings at the applicable social networking site.
- Information you provide to us at seminars or to our partners;
- Information you provide to us in surveys;
- Information that is publicly available; and
- Information you consent to us receiving from third parties.
6.HOW WE USE YOUR INFORMATION
We have a legitimate interest in running a successful and efficient business and in providing you with Services and useful content, and we use the information we collect, both on its own and combined with any other information we collect about you, for the following purposes:
- To provide the requested Services to you;
- To provide you with useful content;
- To ensure the proper functioning of our Services
- To offer and improve our Services;
- To provide you with requested information or technical support
- To facilitate your movement through our websites or your use of our Services;
- To do a better job of advertising and marketing our Services (our use of your information to do this is performed with your consent where required by applicable law);
- To advertise and market third party products and services (such advertisement is only performed with your permission where your consent is required by applicable law)
- To diagnose problems with our servers or our Services;
- In connection with our security and compliance programs;
- To administer our websites;
- To communicate with you;
- To target prospective customers with our products or services (such targeting is only performed with your permission where your consent is required by applicable law);
- To assist us in offering you a personalized experience or otherwise tailor our Services to you; and
We also use the information we receive in aggregated and anonymized formats to produce reports on trends and statistics, such as mobile search trends, email open rates by industry, campaign best practices or the number of users that have been exposed to, or clicked on, our websites or evaluated or purchased our products and services.
Payment information that you provide to us, including credit card data, will only be used to facilitate payment for our products and services.
Payment information that you provide to us, including credit card data, will only be used to facilitate payment for our products and services.
7.SHARING OF INFORMATION
As further described below, we will only share certain personal information only with:
- authorized users within our organization;
- in connection with a sale, merger, acquisition or corporate reorganization;
- for legal reasons.
If we are involved in a merger, acquisition, a sale of all or a substantial portion of our assets, or other similar sale transaction, your information will be transferred as part of that transaction. We will notify you by email and/or a prominent notice on our website of any such transfer and any choices you may have regarding your information.
Lastly, if legally required to do so, or if we have a good faith belief that such disclosure is reasonably necessary, we may disclose your personal information to courts of law, law enforcement authorities and other relevant third parties, such as internet service providers, to conduct an investigation, respond to a third party or law enforcement subpoena or court order, bring legal action, prevent harm to others or pursue other relief when you or a third party are or may be:
- violating our terms and conditions of use;
- causing injury or other harm to, or otherwise violating the property or other legal rights, of us, other users, or third parties; or
- violating federal, state, local, or other applicable law.
This disclosure can include transferring your information to the U.S. and other countries outside the European Economic Area. To the extent we are legally permitted to do so, it is our policy to notify you in the event that we are required to provide your personal information to third parties in connection with a subpoena.
The transmission of information via the internet, email or text message is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted through the Services or over email; any transmission is at your own risk. Once we have received your information, we will take appropriate technical and organizational measures to safeguard your personal information against loss, theft and unauthorized use, access or modification.
When we collect financial account information, such as credit card numbers, we protect its transmission through the use of encryption such as the Transport Layer Security (TLS) protocol.
9.TRACKING TECHNOLOGIES AND ONLINE ADVERTISING
WHAT ARE COOKIES?
Cookies are small data files placed on your computer or other internet-enabled device that enable our features and functionality. They allow us to record information when you visit or interact with our websites, products and services (collectively, our "Websites"). Other tracking technologies, such as web beacons and pixels work similarly to cookies, placing small data files on your device that monitor your Website activity.
WHAT KINDS OF COOKIES AND TRACKING TECHNOLOGIES DO WE USE?
Persistent and Session Cookies
We use two categories of cookies: Persistent cookies and session cookies. Persistent cookies are cookies that help us recognize you. They are stored on your device in between browser sessions, allowing us to remember your preferences and actions across multiple sites and on multiple visits. Session cookies expire at the end of your browser session, allowing us to link your actions during a particular browsing session.
Third Party Cookies
In addition to the first party cookies set by us, we also use third party cookies. Third party cookies are cookies that are set by others, enabling the third party's features or functionalities to be provided through the Website you are using. The third party setting these cookies can recognize your device both when it visits our Website and when it visits certain other websites or services. For example, our paid endorsers, or affiliates, may use third party cookies to identify you as a referral so they can be compensated if you sign up for services from us as a result of visiting one of our paid endorsers. The service providers of third-party cookies have their own privacy policies, and may use their cookies to target advertising to you.
We perform cross-device tracking which allows us to provide more relevant advertising to you on multiple devices. We do this by identifying browsing activity on your smartphones, tablets, desktop computers and other devices connected to the same IP address or logged into the same account to better understand the products and services that might be of interest to you.
Local Storage Objects
We also use Local Storage Objects (LSOs), such as HTML5, to, among other things, optimize screen presentation, video and other preference information.
We use Google Analytics which is a web analytics tool that helps us understand how users engage with our Websites. Like many services, Google Analytics uses first-party cookies to track user interactions as in our case, where they are used to collect information about how users use our Website. This information is used to compile reports and to help us improve our Websites. The reports disclose website trends without identifying individual visitors.
- Strictly Necessary: These cookies and tracking technologies let you navigate our Websites and use essential features, including secure areas and shopping baskets. Without these technologies, we are unable to deliver core functionality of our Websites, products and services to you.
- Performance: These cookies and tracking technologies help us understand how customers and visitors interact with our Websites. They provide us with information about areas of our website visited, time spent on our Websites and any error messages you receive, allowing us to improve the performance of our Websites. They do not collect any information that could identify you.
- Functional: These cookies and tracking technologies are used to provide certain services or to remember settings that will improve your visit, but are not essential to your use of our Websites. They may include personal information that you have disclosed to us.
- Targeting or Advertising: These cookies and tracking technologies allow us to deliver content, including advertisements, relevant to your specific interests. This content may be delivered in our Websites or on third party websites or services. They allow us to understand and improve the relevancy of our advertisements. They may track personal information, including your IP address.
- Social Media Cookies: These cookies are set by third parties, including Facebook and Twitter, and allow you to share what you've been doing on our Websites on social media.
HOW CAN I CONTROL COOKIES?
If you visit our Websites from Europe, only strictly necessary cookies and other tracking technologies will be used on our Websites by default. Other cookies and tracking technologies will only be used when you consent by visiting each Website's Cookie Management Center at http://preferences-mgr.truste.com/
, where available.
Where you visit our Website from outside Europe, the cookies and similar tracking technologies mentioned above will be used by default
Internet browsers allow you to change your cookie settings via the "options" or "preferences" menu in your browser. Please note that if you set your browser to refuse or block all cookies, certain features or functionalities of our Websites will be limited or unavailable to you.
Some internet browsers include the ability to transmit "do not track" signals. Because no industry standard has yet been developed with respect to "do not track," our Websites do not currently process or respond to such "do not track" signals.
You can opt out of Google Analytics without affecting how you visit our site. For more information on opting out of being tracked by Google Analytics across all websites you use, visit this Google page: https://tools.google.com/dlpage/gaoptout
To learn how to manage privacy and storage settings for Flash cookies, visit http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html
Further information about deleting and blocking cookies can be found at http://www.allaboutcookies.com
HOW CAN I GET FURTHER INFORMATION?
COMMUNICATIONS FROM US
You always have the opportunity to opt out of our communications with you or change your preferences by following a link in the footer of all non-transactional email messages from us or by emailing us at firstname.lastname@example.org
. Some communications from us are considered transactional or service communications (for example, important account notifications and billing information), and your account(s) for FLOGEN products and services are provided to you upon the condition that you receive these communications from us. You must cancel your account(s) for FLOGEN products and services, as applicable, if you do not wish to receive any transactional or service communications. To cancel your FLOGEN account(s), please follow the instructions found in the terms of service for the applicable FLOGEN service. You may still receive marketing communications from us even after you cancel your account unless you also opt-out of our marketing communications, as described above.
We may contact you by telephone, with your consent where applicable, for communication purposes (including by automatic dialer and/or prerecorded message). If you do not want to receive communication calls, please contact us at email@example.com
You do not need to agree to receive automated marketing phone calls or texts from us to use the Services.
INFORMATION FROM THIRD PARTIES
If an account or profile was created without your knowledge or authorization, please contact firstname.lastname@example.org
to request removal of the account or profile.
11.RETENTION OF PERSONAL INFORMATION
We retain your personal information to provide services to you and as otherwise necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We will retain your personal information for no more than seven years following the later of (i) the date on which you terminate your use of the Services or (ii) May 25, 2018, unless we are otherwise required by law or regulation to retain your personal information for longer.
Where the European Union's General Data Protection Regulation 2016/679, or GDPR, applies, in certain circumstances and subject to data processing agreements, you have rights in relation to the personal information we hold about you. We set out below an outline of those rights and how to exercise those rights. Please note that we will require you to verify your identity before responding to any requests to exercise your rights by providing details only known to the account holder. Please note that for each of the rights below we may have valid legal reasons to refuse your request, in such instances we will let you know if that is the case.
You have the right to know whether we process personal information about you, and if we do, to access data we hold about you and certain information about how we use it and who we share it with.
You have the right to receive a subset of the personal information you provide us if we process it on the legal bases of our contract with you or with your consent in a structured, commonly used and machine-readable format and a right to request that we transfer such personal information to another party. If you wish for us to transfer the personal information to another party, please ensure you detail that party and note that we can only do so where it is technically feasible. We are not responsible for the security of the personal information or its processing once received by the third party.
You have the right to require us to correct any personal information held about you that is inaccurate and have incomplete data completed. You may exercise your right to restrict our processing of the applicable data as described below.
You may request that we erase the personal information we hold about you in the following circumstances:
- where you believe it is no longer necessary for us to hold the personal information;
- we are processing it on the basis of your consent and you wish to withdraw your consent;
- we are processing your data on the basis of our legitimate interest and you object to such processing;
- you no longer wish us to use your data to send you marketing; or
- you believe we are unlawfully processing your data.
Please provide as much detail as possible on your reasons for the request to assist us in determining whether you have a valid basis for erasure.
RESTRICTION OF PROCESSING TO STORAGE ONLY
You have a right to require us to stop processing the personal information we hold about you other than for storage purposes in the following circumstances:
- You believe the personal information is not accurate for the period it takes for us to verify whether the data is accurate;
- We wish to erase the personal information as the processing we are doing is unlawful but you want us to simply restrict the use of that data;
- We no longer need the personal information for the purposes of the processing but you require us to retain the data for the establishment, exercise or defense of legal claims; or
- You have objected to us processing personal information we hold about you on the basis of our legitimate interest and you wish us to stop processing the personal information while we determine whether there is an overriding interest in us retaining such personal information.
You have the right to object to our processing of data about you and we will consider your request. Please provide us with detail as to your reasoning so that we can assess whether there is a compelling overriding interest in us continuing to process such data or we need to process it in relation to legal claims.
You also have the right, at any time, to object to our processing of data about you in order to send you marketing, including where we build profiles for such purposes and we will stop processing the data for that purpose.
WITHDRAWAL OF CONSENT
Where you have provided your consent to us processing your personal data, you can withdraw your consent at any time by contacted us at email@example.com
12. THIRD PARTY LINKS AND INFORMATION COLLECTION AND USE BY OUR USERS
Some of our Services provide links to other websites. Because we do not control the information policies or practices of these third party sites, you should review their privacy policies to learn about how they collect and use personal information.
Our Services are not directed to persons under 18. We do not knowingly collect personal information from children under 18. If a parent or guardian becomes aware that his or her child has provided us with personal information without such parent or guardian's consent, he or she should contact us. If we become aware that a child under 18 has provided us with personal information, we will delete such information from our files.
In order for us to provide the Services to you, your personal information will be transferred to, and stored at/processed in Canada. We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this policy.
For transfers of data to third parties, such transfers will either (i) be under the Commission's model contracts for the transfer of personal data to third countries (i.e., the standard contractual clauses), pursuant to Decision 2004/915/EC and 2010/87/EU; or (ii) rely on the EU-US Privacy Shield Framework.
You can contact the Data Protection Officer listed below to obtain a copy of the data transfer agreement or more information regarding the relevant safeguards we put in place.
In the event that you wish to make a complaint about how we process your personal information, please contact our Data Protection Officer at firstname.lastname@example.org
and we will try to deal with your request. This is without prejudice to your right to raise a complaint with the relevant supervisory authority of your habitual residence.
16.NOTIFICATION OF CHANGES
or the website of the FLOGEN product or service you used prior to the change becoming effective. In all cases, your continued use of any Services constitutes acceptance to any such changes.
Last modified May 25, 2018
Privacy Contact Information
FLOGEN Technologies Inc.
1255 Laird Blvd., Ste.388-1
Mont-Royal, Qc, Canada, H3P 2T1