Why does the Company collect personal information?
The Company may collect personal information for the following purposes:
To administer, plan, and manage the relationship with individuals and to communicate with individuals;
To provide individuals with requested information, products, and/or services;
To better understand how the Company may improve its products and services, to develop and conduct its business and operations, and for other internal business purposes;
To provide individuals with information on current and future products and services or other developments with respect to the Company and its affiliates and partners (in accordance with Canada’s Anti-Spam Legislation – see below); and
To comply with applicable legal and regulatory requirements or to protect the Company’s legal rights and property;
(collectively, the “Authorized Purposes”).
The type of information that the Company may collect from individuals includes, for example, name, email address, address, phone number, and other information individuals choose to provide.
The Company may collect personal information for other purposes where it has a legal duty or right to do so or where the Company has a good faith belief that it is necessary to protect the property or rights of the Company.
The Company does not collect personal information for any other purposes, unless it has the consent of the individual to whom it relates.
How does the Company collect personal information?
The Company only collects personal information about an individual with the individual’s knowledge and consent. Generally, this means that the Company collects personal information directly from the individual to whom it relates, whether via the Ego-Less application as well as any related websites and services including external social media sites (the "Platform"), or by e-mail, telephone, fax, or in person. Occasionally, the Company may collect personal information from third party sources, but only with the knowledge and consent of the individual or where otherwise authorized by law.
Users of the Platform should also be aware that anonymous technical information may be collected by the Company as a result of use of the Platform. For example, this information may include the visitor’s IP address, browser type, operating system, system performance information, domain name, access times and referring website addresses. The Company uses this anonymous technical information for purposes such as diagnosing problems with the Company’s servers, improving the operation and content of the Platform and compiling aggregate and statistical information.
In particular, the Company may use certain tracking and analytics services:
The Company uses “cookies” on its Platform. “Cookies” are small text files placed on computers that can collect and store a variety of information. Permanent cookies are stored indefinitely on a user’s hard drive unless manually deleted, while temporary cookies are automatically deleted from the user’s browser upon logging out of a website. Web browsers typically allow users to disable permanent and/or temporary cookies.
The Company and its analytics partners use technologies such as cookies, beacons, tags, and scripts to enable a service to recognize your device to minimize the number of times you have to provide the same data and to measure how people are using the Platform.
The company uses mobile analytics software to allow us to better understand the functionality of our mobile software on your device. This software records information such as how often you engage with the app, the events that occur within the app, usage and performance data.
The Company uses Google Analytics. There is more information about how Google collects, uses, and processes data here.
The Company will not attempt to link or match such anonymous technical information with any personally-identifiable information unless the Company has an individual’s consent, the Company (or its service providers) have detected or reasonably suspect any unlawful use of the Company’s services or a security breach, or the Company has a legal duty or right to do so.
When does the Company use or disclose personal information?
The Company only uses or discloses personal information as reasonably required to facilitate the Authorized Purposes listed above.
In some cases, the Company may share personal information with third party service providers performing functions on the Company’s behalf, including, for example, vendors that provide information technology services or provide analytics or assessment services (for example, developers, hosting site, analytics service providers, and payment service provider).
The Company does not otherwise use or disclose personal information unless the Company has an individual’s consent, the Company has a good faith belief that disclosure of the information is necessary to protect the rights or property of Company, or the Company has a legal duty or right to do so.
The Company does not rent, sell or trade customer lists or other personal information.
Consent – Is there a choice?
Individuals provide their consent to the collection, use, and disclosure of personal information by the Company when they provide their information to the Company or use its products or services.
Individuals can deny or withdraw their consent to the Company’s collection, use and disclosure of their personal information at any time upon reasonable notice, subject to any legal or contractual requirements. However, if consent is denied or withdrawn, the Company may not be able to provide certain products or services.
The Company and its affiliates may use personal information to inform individuals of current and/or new products or services or other developments that the Company or its affiliates or partners believe will be of interest to individuals in accordance with Canada’s Anti-Spam Legislation. Such communications may be made by way of telephone, text message, direct messaging, e-mail, fax or regular mail. Individuals provide their consent to the Company and its affiliates and partners contacting them in this manner when they use the Company’s products or services. Individuals may opt-out of receiving such communications by contacting the Company at the address below.
How does the Company protect the security of personal information?
The Company has in place reasonable policies, procedures and safeguards (including physical, technological and organizational measures) designed to protect the security of personal information under its control.
The protection of personal information is of paramount concern to the Company, and the Company is prepared to take appropriate and timely steps in the event of any incidents involving personal information in accordance with applicable privacy laws.
The Company makes every reasonable effort to ensure that personal information is accurate and complete. This may involve requesting further information or updates from individuals. The Company relies on individuals to notify the Company if there is a change to their personal information that may affect their relationship with the Company.
The Company retains personal information only as long as is reasonable to fulfill the purposes for which the information was collected, or for legal or business purposes.
Does the Company provide access to personal information?
The Company will provide individuals with access to the personal information the Company holds about them in accordance with applicable laws. The Company reserves the right to require that any request for access to personal information be made in writing. Generally, there is no cost for such access. However, the Company reserves the right to charge such costs on a case by case basis in accordance with applicable laws. The individual will be notified in advance if charges apply.
The Company will correct or amend the personal information in its files where it can be shown that the information is incorrect or incomplete.
Storage and Processing
The Company will store the personal information on its internal servers and/or with its services providers.
The Company’s service providers may store and/or process personal information outside of Canada (including in the United States of America). When information is stored or processed outside of Canada, it may be subject to the laws of and be accessible by legal authorities in such other jurisdictions. The Company has taken appropriate technical, organizational, and legal steps to secure this information.
Your Rights relating to your Personal Data
Subject to some exceptions, the GDPR provides you with the following rights:
Right of access: You have the right to information about whether and why we process your personal data and related information (for example, what personal data we are processing).
Right of rectification: You have the right to correct any inaccurate or incomplete personal data that we hold about you.
Right to erasure: You have the right to ask us to delete personal data that we hold about you.
Right to restrict or object to processing: You have the right to ask us to limit or stop our processing of your personal data in certain cases (for example, if the personal data we are processing about you is inaccurate or is for direct marketing purposes).
Right to data portability: You have the right to ask us for a copy of personal data we hold about you and to transfer such data to another entity.
Right to complain: We encourage you to contact us at the contact information below if you have any questions or concerns with our personal data practices. However, you also have the right to complain to regulatory authorities in your jurisdiction. Please contact us at the contact information below if you need information about the appropriate authority.
You may exercise these rights or find out more about these rights by contacting the Company at the contact information listed below.
Retention and Storage of Personal Data
The Company is based in Canada and processes personal data in Canada. The European Commission recognizes Canada as providing an adequate level of protection for personal data. The Company's service providers may process your personal information outside of Canada (such as in the United States of America). When your information is processed outside of the European Union, it may be subject to the laws of and be accessible by legal authorities in such other jurisdictions. The Company has taken appropriate technical, organizational, and legal steps to secure this information.
Contact the Company
For further information about the Company’s privacy practices, to make a request for access to personal information to exercise any other rights outlined above, please contact the Company’s Privacy Officer at .
The foregoing policy is effective as of October 3, 2020. The Company reserves the right to change this policy at any time in accordance with applicable laws – please check our website for updates to this policy.