Privacy Policy – Pensionbar
Last modified: Apr
22, 2021
Pensionbar Inc. and
our affiliates and subsidiaries (“Company”
or “We”) respect your privacy
and are committed to protecting it by complying with this policy.
This policy describes:
· How we collect, use,
disclose, and protect the personal information of our customers and website
users (“you”).
· Describes the types of
information we may collect from you or that you may provide when you visit the
website pensionbar.ca (our “Website”).
· Our practices for
collecting, using, maintaining, protecting, and disclosing that information.
We will only use
your personal information in accordance with this policy unless otherwise
required by applicable law. We take steps to ensure that the personal
information that we collect about you is adequate, relevant, not excessive, and
used for limited purposes.
Privacy laws in
Canada generally define “personal information” as any information about an
identifiable individual, which includes information that can be used on its own
or with other information to identify, contact, or locate a single person.
This policy applies
to information we collect, use, or disclose about you:
· On this Website.
· In email, text, and other
electronic messages between you and this Website.
· Through mobile and web-based
applications you access from this Website
· When you interact with
our advertising and applications on third-party websites and services if those
applications or advertising include links to this policy.
The Website may
include links to third-party websites, plug-ins, services, social networks, or
applications. Clicking on those links or enabling those connections may allow
the third party to collect or share data about you. If you follow a link to a
third-party website or engage a third-party plugin, please note that these
third parties have their own privacy policies and we do not accept any
responsibility or liability for these policies. We do not control these
third-party websites, and we encourage you to read the privacy policy of every
website you visit.
This policy DOES
NOT apply to information that:
· We collect offline or
through any other means, including on any other Company or third-party website
(including our affiliates and subsidiaries).
· You provide to or is
collected by any third party (including our affiliates and subsidiaries),
through any application or content (including advertising) that may link to or
be accessible from or on the Website.
·
Please read this
policy carefully to understand our policies and practices for collecting,
processing, and storing your information. If you do not agree with our policies
and practices, your choice is not to use our Website. By accessing or using
this Website, you indicate that you understand, accept, and consent to the
practices described in this policy. This policy may change from time to time
(see Changes to Our Privacy Policy). Your continued use of this Website after
we make changes indicates that you accept and consent to those changes, so
please check the policy periodically for updates.
INFORMATION WE COLLECT ABOUT YOU
We collect and use
several types of information from and about you, including:
· Personal information, that we can reasonably use to directly or
indirectly identify you, such as your name, mailing address, e-mail address,
telephone number, Internet protocol (IP) address used to connect your computer
to the Internet, username or other similar identifier, and any other identifier
we may use to contact you (“personal
information”).
We provide an
opportunity for any user to unsubscribe from our application or opt-out of
contact for marketing purposes on an ongoing basis by e-mailing to [email protected].
· Non-personal information, that does not directly or indirectly
reveal your identity or directly relate to an identifiable individual, such as
age or salary amount, demographic information, or statistical or aggregated
information. Statistical or aggregated data does not directly identify a
specific person, but we may derive non-personal statistical or aggregated data
from personal information. For example, we may aggregate personal information
to calculate the percentage of users accessing a specific Website feature.
· Technical information, including your login information, browser
type and version, time zone setting, browser plug-in types and versions,
operating system and platform, or information about your internet connection,
the equipment you use to access our Website, and usage details.
· Non-personal details about your Website interactions, including the
full Uniform Resource Locators (URLs), clickstream to, through and from our
Website (including date and time), products you viewed or searched for, page
response times, download errors, length of visits to certain pages, page
interaction information (such as scrolling, clicks, and mouse-overs), methods
used to browse away from the page, or any phone number used to call our
customer service number.
HOW WE COLLECT INFORMATION ABOUT YOU
We use different
methods to collect your information, including through:
· Direct interactions with you when
you provide it to us, for example, by filling in forms, interacting with
the app, or corresponding with us by phone, email, or otherwise.
· User contributions. You may also provide information for us to
publish or display on public Website areas or transmit to other Website users
or third parties.
· Automated technologies or interactions, as you navigate through our
Website. Information collected automatically may include usage details, IP
addresses, and information collected through cookies and other tracking
technologies.
· Third parties or publicly available sources, for example, our
business partners.
The information we
collect directly from you on or through our Website may include:
· Information that you
provide by filling in forms or interacting with the app on our Website. This
includes information provided at the time of interacting with the app, registering
to use our Website, posting material, and requesting further services. We may
also ask you for information when you enter a contest or promotion sponsored by
us, and when you report a problem with our Website.
· Records and copies of
your correspondence (including email addresses), if you contact us.
· Your responses to surveys
that we might ask you to complete for research purposes.
· Details of transactions
you carry out through our Website and of the fulfillment of your orders. You
may be required to provide financial information before placing an order
through our Website.
You may
also provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website
or transmitted to other users of the Website or third parties (collectively, “User Contributions”). Your User
Contributions are posted on and transmitted to others at your own risk.
Although [we limit access to certain pages/you may set certain privacy settings
for such information by logging into your account profile], please be aware
that no security measures are perfect. Additionally, we cannot control the
actions of other users of the Website with whom you may choose to share your
User Contributions. Therefore, we cannot and do not guarantee that unauthorized
persons will not view your User Contributions.
Information
We Collect Through Cookies and Other Automatic Data Collection Technologies
As you navigate
through and interact with our Website, we may use cookies or other automatic
data collection technologies to collect certain information about your
equipment, browsing actions, and patterns, including:
· Details of your visits to
our Website, including location data and other communication data and the
resources that you access and use on the Website.
· Information about your
computer and internet connection, including your IP address, operating system,
and browser type.
The information we
collect automatically is statistical data and does not include personal
information, and we may maintain it or associate it with personal information
we collect in other ways, that you provide to us, or receive from third parties.
It helps us to improve our Website and to deliver a better and more
personalized service, including by enabling us to:
· Estimate our audience
size and usage patterns.
· Store information about
your preferences, allowing us to customize our Website according to your
individual interests.
· Speed up your searches.
· Recognize you when you
return to our Website.
The technologies we
use for this automatic data collection may include:
· Cookies (or browser cookies). A cookie is a small file placed on the
hard drive of your computer. You may refuse to accept browser cookies by
activating the appropriate setting on your browser. However, if you select this
setting you may be unable to access certain parts of our Website. Unless you
have adjusted your browser setting so that it will refuse cookies, our system
will issue cookies when you direct your browser to our Website.
· Flash Cookies. Certain features of our Website may use local stored
objects (or Flash cookies) to collect and store information about your
preferences and navigation to, from, and on our Website. Flash cookies are not
managed by the same browser settings that are used for browser cookies. For
information about managing your privacy and security settings for Flash
cookies, see Choices About How We
Use and Disclose Your Information.
· Web Beacons. Pages of our Website and our e-mails may contain small
electronic files known as web beacons (also referred to as clear gifs, pixel
tags, and single-pixel gifs) that permit the Company, for example, to count
users who have visited those pages or opened an email and for other related
website statistics (for example, recording the popularity of certain website
content and verifying system and server integrity).
We use information
that we collect about you or that you provide to us, including any personal
information:
· To present our Website
and its contents to you.
· To provide you with
information, products, or services that you request from us.
· To fulfill the purposes
for which you provided the information or that were described when it was
collected, or any other purpose for which you provide it.
· To provide you with
notices about your account
· To carry out our
obligations and enforce our rights arising from any contracts with you,
including for billing and collection or to comply with legal requirements.
· To notify you about
changes to our Website or any products or services we offer or provide though
it.
· To improve our Website,
products or services, marketing, or customer relationships and experiences.
· To allow you to
participate in interactive features, social media, or similar features on our
Website.
· To measure or understand
the effectiveness of the advertising we serve to you and others, and to deliver
relevant advertising to you.
· In any other way we may
describe when you provide the information.
· For any other purpose
with your consent.
We may also use
your information to contact you about our goods and services that may be of
interest to you, as permitted by law. If you do not want us to use your
information in this way, please e-mail us at [email protected]. For more
information, see Choices About How We
Use and Disclose Your Information.
We may
use the information we have collected from you to enable us to display
advertisements to our advertisers’ target audiences. Even though we do not
disclose your personal information for these purposes without your consent, if
you click on or otherwise interact with an advertisement, the advertiser may
assume that you meet its target criteria.
DISCLOSURE OF YOUR INFORMATION
We may disclose
aggregated information about our users, and information that does not identify
any individual, without restriction.
We may disclose
personal information that we collect or you provide as described in this
privacy policy:
· To our subsidiaries and
affiliates.
· In accordance with
applicable law, to a buyer or other successor in the event of a merger,
divestiture, restructuring, reorganization, dissolution, or other sale or
transfer of some or all of Pensionbar Inc.’s assets, whether as a going concern
or as part of bankruptcy, liquidation, or similar proceeding, in which personal
information held by Pensionbar Inc. about our customers and users is among the
assets transferred.
· To advertisers and
advertising networks that require the information to select and serve relevant
advertisements to you and others. We do not disclose data about identifiable individuals
to our advertisers, but we may provide them with aggregate information about
our users (for example, we may inform them that 400 women between 30 and 45
have clicked on their advertisement on a specific day). We may also use such
aggregate information to help advertisers target a specific audience (for
example, men in a specific location). We may make use of the personal
information we have collected from you to enable us to display our advertisers’
advertisement to that target audience.
· To third parties to
market their products or services to you if you have consented to these
disclosures.
· To contractors, service
providers, and other third parties we use to support our business (such as
analytics and search engine providers that assist us with Website improvement
and optimization) and who are contractually obligated to keep personal
information confidential, use it only for the purposes for which we disclose it
to them, and to process the personal information with the same standards set out
in this policy.
· To fulfill the purpose
for which you provide it.
· For any other purpose
disclosed by us when you provide the information.
· With your consent.
·
We may also
disclose your personal information:
· To comply with any court
order, law, or legal process, including to respond to any government or
regulatory request, in accordance with applicable law.
· To enforce or apply our terms
of use and other
agreements, including for billing and collection purposes.
· If we believe disclosure
is necessary or appropriate to protect the rights, property, or safety of Pensionbar
Inc., our customers, or others.
TRANSFERRING YOUR PERSONAL INFORMATION
We may transfer
personal information that we collect or that you provide as described in this
policy to contractors, service providers, and other third parties we use to
support our business (such as analytics and search engine providers that assist
us with Website improvement and optimization) and who are contractually
obligated to keep personal information confidential, use it only for the
purposes for which we disclose it to them, and to process the personal
information with the same standards set out in this policy.
We may process,
store, and transfer your personal information in and to a foreign country, with
different privacy laws that may or may not be as comprehensive as Canadian law.
In these circumstances, the governments, courts, law enforcement, or regulatory
agencies of that country may be able to obtain access to your personal
information through the laws of the foreign country. Whenever we engage a
service provider, we require that its privacy and security standards adhere to
this policy and applicable Canadian privacy legislation.
By submitting your
personal information or engaging with the Website, you consent to this
transfer, storage, or processing.
CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION
We strive to
provide you with choices regarding the personal information you provide to us.
We have created mechanisms to provide you with the following control over your
information:
· Tracking Technologies and Advertising. You can set your browser to
refuse all or some browser cookies, or to alert you when cookies are being
sent. To learn how you can manage your Flash cookie settings, visit the Flash
player settings page on Adobe’s website. If you disable or refuse cookies,
please note that some parts of this Website may not be accessible or may not
function properly. For more information about tracking technologies, see Information We Collect Through
Cookies and Other Automatic Data Collection Technologies.
· Third-Party Advertising. If you do not want us to share your
personal information with unaffiliated or non-agent third parties for
promotional purposes, you can opt-out by checking the relevant box located on
the form where we collect your data.
· Promotional Offers from the Company. If you have opted in to
receive certain emails from us but no longer wish to have your email address
used by the Company to promote our own or third parties’ products or services,
you can opt-out by sending us an email stating your request to [email protected].
If we have sent you a promotional email, you may unsubscribe by clicking the
unsubscribe link we have included in the email. This opt-out does not apply to
information provided to the Company as part of a product purchase, warranty
registration, product service experience, or other transactions.
DATA SECURITY
The security of
your personal information is very important to us. We use physical, electronic,
and administrative measures designed to secure your personal information from
accidental loss and from unauthorized access, use, alteration, and disclosure.
We store all information you provide to us behind firewalls on our secure
servers. Any payment transactions and OTHER INFORMATION will be encrypted using
SSL technology.
The safety and
security of your information also depends on you. Where we have given you (or
where you have chosen) a password for access to certain parts of our Website,
you are responsible for keeping this password confidential. We ask you not to
share your password with anyone.
Unfortunately, the
transmission of information via the Internet is not completely secure. Although
we do our best to protect your personal information, we cannot guarantee the
security of your personal information transmitted to our Website. Any
transmission of personal information is at your own risk. We are not responsible
for circumvention of any privacy settings or security measures contained on the
Website.
Except as otherwise
permitted or required by applicable law or regulation, we will only retain your
personal information for as long as necessary to fulfill the purposes we
collected it for, including for the purposes of satisfying any legal,
accounting, or reporting requirements. Under some circumstances we may
anonymize your personal information so that it can no longer be associated with
you. We reserve the right to use such anonymous and de-identified data for any
legitimate business purpose without further notice to you or your consent.
Our Website is not
intended for children under 13 years of age. No one under age 13 may provide
any personal information to or on the Website. We do not knowingly collect
personal information from children under 13. If you are under 13, do not use or
provide any information on this Website or on or through any of its
features/register on the Website, make any purchases through the Website, 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 username you may use. If we learn
we have collected or received personal information from a child under 13
without verification of parental consent, we will delete that information. If
you believe we might have any information from or about a child under 13,
please contact us at [email protected].
ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION
It is important
that the personal information we hold about you is accurate and current. Please
keep us informed if your personal information changes. By law you have the
right to request access to and to correct the personal information that we hold
about you.
If you want to
review, verify, correct, or withdraw consent to the use of your personal
information you may also send us an email at [email protected] to request
access to, correct, or delete any personal information that you have provided
to us. We cannot delete your personal information except by also deleting your
user account. We may not accommodate a request to change information if we
believe the change would violate any law or legal requirement or cause the
information to be incorrect.
We may request
specific information from you to help us confirm your identity and your right
to access, and to provide you with the personal information that we hold about
you or make your requested changes. Applicable law may allow or require us to
refuse to provide you with access to some or all of the personal information
that we hold about you, or we may have destroyed, erased, or made your personal
information anonymous in accordance with our record retention obligations and
practices. If we cannot provide you with access to your personal information,
we will inform you of the reasons why, subject to any legal or regulatory
restrictions.
We will provide
access to your personal information, subject to exceptions set out in
applicable privacy legislation. Examples of such exceptions include:
· Information protected by
solicitor-client privilege.
· Information that is part
of a formal dispute resolution process.
· Information that is about
another individual that would reveal their personal information or confidential
commercial information.
· Information that is prohibitively
expensive to provide.
If you are
concerned about our response or would like to correct the information provided,
you may contact our Privacy Officer, Leyla Imanirad at [email protected].
If you delete your
User Contributions from the Website, copies of your User Contributions may
remain viewable in cached and archived pages or might have been copied or
stored by other Website users. Proper access and use of information provided on
the Website, including User Contributions, is governed by our terms
of use.
Where you have
provided your consent to the collection, use, and transfer of your personal
information, you may have the legal right to withdraw your consent under
certain circumstances. To withdraw your consent, if applicable, contact us at
[email protected]. Please note that if you withdraw your consent, we may
not be able to provide you with a particular product or service. We will
explain the impact to you at the time to help you with your decision.
It is our policy to
post any changes we make to our privacy policy on this page. If we make
material changes to how we treat our users’ personal information, we will notify
you by email to the primary email address specified in your account and through
a notice on the Website home page.
We include the date
the privacy policy was last revised at the top of the page. You are responsible
for ensuring we have an up-to-date, active, and deliverable email address for
you, and for periodically visiting our Website and this privacy policy to check
for any changes.