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Causable Privacy Policy

Last Updated: July 2024

YOUR USE OF THIS WEBSITE SIGNIFIES YOUR AGREEMENT WITH THE TERMS OF THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY, PLEASE DO NOT USE THIS WEBSITE OR SUBMIT PERSONAL INFORMATION TO US.

  1.  INTRODUCTION

Causable Inc. (“we” or “us”), is committed to protecting the privacy of our users, subscribers to our newsletters and publications, registrants for our and visitors to this website (the “Website”) in accordance with Provincial and Federal applicable privacy legislation, including the Personal Information Protection and Electronic Documents Act, (“PIPEDA”). If you do not agree with any terms of this Privacy Policy, please do not use this Website or submit any Personal Information to us, our service providers or agents.

The purpose of this Privacy Policy is to give you information about what Personal Information Causable Inc collects from you, why we collect it and how we use it, as well as what happens if you choose not to disclose certain Personal Information to us. We collect information with regard to the Website, and all mobile applications that refer to or link to the Website including all information, software, products and features available from the Website or offered as part of or in conjunction with the use of the services, hereinafter all referred to as the” Website.”

This Privacy Policy is based on the principles outlined in the Canadian Standards Association’s Model Code for the Protection of Personal Information, set out in Schedule 1 of PIPEDA. We will only collect, use and disclose your Personal Information in accordance with this Privacy Policy. This Privacy Policy applies to any Personal Information provided to or collected by Causable Inc. through this Website.

We may make changes to this Policy from time to time, such as in response to developments and changes in privacy law. When we post changes to this Policy on our Website, we will change the “Last updated” date at the top of this Policy. If possible, we will post notices of significant changes before they take place. Your continued use of this Website after any changes are made signifies your agreement with the terms of the update Policy.

  1.  WHAT IS PERSONAL INFORMATION?

Personal Information is information about an identifiable individual, including any information about you or that can be used to identify you. For the purposes of this Privacy Policy, Personal Information means any information provided to or collected by Causable Inc, our service providers (“Service Providers”) or agents about an identifiable individual and applies regardless of how the information is collected. Whether you access the Website from your computer, smart phone, tablet or other mobile or computing device, Causable or third parties working on our behalf (“Service Providers”) collects information to manage our relationship with you and to consistently deliver high quality products and services. 

However, Personal Information does not generally include business contact information, including your name or the name of your business or organization, job title or position, mail and e-mail addresses, business telephone or facsimile numbers.

  1. WHAT IS NOT PERSONAL INFORMATION?

We collect data elements (“Non-Personal Information”) that do not reveal your identity or that do not relate directly to you or any other individual, such as browser and device information, including operating system, demographic information such as occupation, language, interests, the first three digits of your postal code, unique device identifier, and transactional data.  This includes other information provided by you, mobile application usage data aggregated information such as “clickstream” information such as entry and exit points for the Services (including referring URLs or domains), certain traffic statistics, page views, and impressions relating to the Services, and information collected through Cookies (as defined below), pixel tags and other technologies described in more detail later in this Privacy Policy. Causable may also make certain aggregated Non-Personal Information available to strategic partners and third-party Service Providers that work with Causable, to provide or support our or their products and services or that help Causable or its strategic partners and third-party service providers to conduct data analysis, to develop and improve products and services, and determine the effectiveness of promotional campaigns. We reserve the right to use and share any such Non-Personal Information with third parties for any lawful purpose. 

  1.  WHAT PERSONAL INFORMATION DO WE COLLECT?

Personal information we collect may identify you or relate to you as an individual, such as your name, mailing address, telephone number, e-mail address, for account registration and administration), device ID, including IP address, geolocation (if using a mobile application and you consent to providing it), payment card or financial account information and other payment information (that you submit to us for order processing) and additional Personal Information necessary for the administration of certain services pertaining to the use of the Website.  

Causable Inc., our Service Providers and agents may collect additional information in  the course of our normal operations and providing our services including: (i) background information or identification data such as your date of birth, copies of your driver’s license or passport or copies of utility bills, (ii) Information regarding your organization, including information regarding directors, officers,members or employees, (iv) Website usage and other technical information that is automatically sent to us by your web browser or collected through cookies and other similar technology when you visit our Website, and any other information that you may provide. 

  1. HOW DO WE COLLECT PERSONAL INFORMATION?

Causable Inc., our Service Providers and agents may collect Personal Information in different ways:

a) Directly. You may voluntarily provide us with Personal Information when you access our Website, register for an account, fill out forms or sign documents, pay for your account with us through the use of a payment processor platform, or communicate with us via video conference, telephone or  email.

b) Automatically. As you use our Website, we may automatically collect technical information about your equipment and browsing history, using cookies or similar technologies. 

c) Indirectly. From third parties, when we collect information as part of our user acceptance procedures, or should we receive information about you from third parties such as regulatory authorities, government agencies, Service Providers or agents (such as our payment processor), publicly available records or other professionals or lawyers in connection with the services provided to you.   

  1.  ACCOUNTABILITY

Causable Inc. is responsible for Personal Information under our control. We have designated a Privacy Officer to be accountable for our compliance and to oversee any questions relating to privacy or this Privacy Policy. If you have any questions about this Privacy Policy, including how to exercise your legal rights, or if you would like specific information about how we manage Personal Information, please contact our  Privacy Officer at:

_______________

Chris Weeks

Atlantic Technology Centre

176 Great George Street, Suite310, Charlottetown, PE C1A 4K9

privacy@causable.io

6.1 IDENTIFYING PURPOSES

Causable Inc. identifies the purposes for which Personal Information is collected at or before the time the information is collected. We collect Personal Information to manage our operations and only for purposes that a reasonable person would consider appropriate in the circumstances. 

The main reasons for collecting Personal Information may be: (i) to conduct and administer our business operations, (ii) to perform or carry out the terms of any contract between us, (iv) to organize, promote and provide conferences, webinars and other gaming events, (v) to record whether you have subscribed or unsubscribed from any of our mailing lists or publications, (vi) to process your requests when you register for an account or subscribe for one of our publications, (vii) to respond to your inquiries, (vI) to provide, administer and protect our Website including troubleshooting, data analysis, maintenance and network security (vii) to deliver relevant Website content and to respond to requests for information or inquiries from visitors to the Website, (viii) for marketing and business development purposes, in order to promote our services and to send out updates (with consent under Canada’s Anti-Spam Law), (ix) to monitor the quality of our work and to better understand your needs so that we can improve our services, (x) to disclose or share your Personal Information when required to comply with legal or regulatory requirements, (xi) to perform user due diligence, identification verification, screening and relevant background checks as may be required or advisable and as the case may be to identify conflicts of interests, (xii) to prevent and detect fraud and other crimes such as terrorism financing or money laundering, (xiii) for billing and collection purposes, (ixv) for other purposes that we tell you about and for which you give us your consent and (xv) and)to fulfill other purposes permitted or required by law. Causable Inc. does not collect more Personal Information than we need to achieve these purposes.

6.2 CONSENT

Causable Inc. only collects, uses and discloses Personal Information with your knowledge and consent, unless authorized or required by law to do so without consent. Your consent may be expressed orally, electronically or in writing or it may be implied. By providing Personal Information to us, whether through the Website, by email, in person or by any other means, you signify your consent to our collection, use and disclosure of your Personal Information with respect to  this Privacy Policy and as otherwise permitted or required by law. If you do not agree with any terms of this Privacy Policy, please do not use the Website or submit any Personal Information to us.

You have the right at any time to withdraw or cancel your consent to the collection, use or disclosure of your Personal Information by contacting Causable’s Privacy Officer. Withdrawals of consent only take effect from the date of cancellation and cannot be retroactive. We will let you know if your withdrawal could have any consequences, such as Causable being unable to provide you with services.

6.3 LIMITED COLLECTION

Causable Inc. only collects Personal Information for the purposes identified in this Privacy Policy. For any other purpose, we will tell you what that purpose is and obtain your consent. We do  not collect, use or disclose more Personal Information than is reasonably necessary to meet the purposes identified by Causable. 

6.4 LIMITED USE OR DISCLOSURE

Causable Inc.  will only use or disclose Personal Information for the purposes for which it was collected, unless we have your consent to use it for a different purpose or if we are required by law. If we want to use or disclose your Personal Information for a new purpose, we will advise you of this purpose in writing and obtain your consent.

We keep Personal Information only as long as necessary to achieve the purposes for which it was collected although we may retain certain Personal Information indefinitely if we are required to do so by Canada Revenue Agency or by our insurers. If you have made a request to access Personal Information, we will keep that Personal Information for as long as is necessary to allow you to fully seek any remedies (exhaust any recourse) that you may have under federal and provincial legislation across Canada.

We do not disclose or share Personal Information more widely than is necessary to achieve the purposes for which it was collected.

We may share Personal Information with the parties set out below for the following purposes:

  1. Third-party service providers, such as those who provide us with IT and system administration services, data analytics services, credit card and payment processing services, e-commerce services, and database management services.
  2. Professional advisors, such as management consultants, auditors, bankers and insurers who provide us with accounting, auditing, banking and insurance services.
  3. Government, regulatory authorities, law enforcement, dispute resolution bodies, courts and similar entities to comply with any legal or regulatory obligation, to detect and prevent crimes or to assert or defend legal rights and interests.
  4. Any persons or entities where we have a legitimate business reason for doing so, such as to manage risk, to process payments to you or to someone on your behalf or to perform or carry out the terms of any contract between us.
  5. To anyone we reasonably believe is your agent.
  6. To other third parties if we have told you about them and you have given us your consent.

We require all third parties to respect the security of your Personal Information and to treat it in accordance with all applicable legal requirements. Service Providers are required to enter into contractual agreements with us that prevent them from using your Personal Information for their own purposes and require them to use your Personal Information only for specific purposes in accordance with our instructions and all applicable legal requirements.

6.5 UPDATING PERSONAL INFORMATION

We follow adequate processes and have safeguards in place to keep Personal Information as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used. We will not routinely update Personal Information, unless such a process is necessary to fulfill the purposes for which the Personal Information was collected. To change or modify any Personal Information previously provided to us, contact the Privacy Officer.

6.6 SAFEGUARDS

We take all reasonable steps to keep Personal Information in both paper and electronic format protected against loss, theft, snooping, hacking or people collecting, disclosing, copying, using or changing it without authorization. We use security safeguards appropriate to the sensitivity of the information. Our methods of protection include:

  1. Physical requirements, including  areas of restricted access and locked filing cabinets.
  2. Operational requirements, including security policies and procedures, employee training on privacy issues, security clearances and limiting access on a “need-to-know” basis.
  3. Technological requirements, pertaining to  passwords, encryption, audits as well as strong data security software and systems to protect the Personal Information in our custody from hackers and malicious intruders. Our software is routinely updated to maximize protection of Personal Information. We may safely destroy Personal Information so that reconstruction is not reasonably possible. This prevents unauthorized parties from gaining access to the Personal Information. 
  4. Human Resources requirements. We make all employees as well as third-party service providers aware of the importance of maintaining the privacy and security of Personal Information. All Causbale Inc. employees must sign a confidentiality agreement. We require all third-party Service Providers to enter into contractual agreements that require them to respect the security of your Personal Information and to treat it in accordance with all applicable legal requirements.
  5. Security requirements. While we are committed to protecting your Personal Information, our security practices and technology measures cannot guarantee absolute security of Personal Information and we cannot ensure or warrant the security of any information you provide to us. You can reduce risk to your own Personal Information by using strong passwords, keeping your passwords confidential and following other Personal Information security best practices.

6.7 ACCESS AS A PERSONAL INFORMATION SUBJECT

You can request access to the Personal Information that we keep, how we use it and to whom it may have been disclosed, by making a request to the Privacy Officer at any time.  If  you make a request to the Privacy Officer, we will inform you of the existence, use, and disclosure of your Personal Information and we will give you access to your Personal Information except in certain circumstances, such as if the disclosure of your records would breach solicitor-client privilege. We will respond to your request within the reasonable  time periods provided for under applicable laws.

6.8 ERRORS AND OMISSIONS

You can challenge the accuracy and completeness of the Personal Information and have it changed or corrected as appropriate if there is an error or omission by contacting the Privacy Officer. We will respond to your request within the time periods provided for under applicable laws. If we identify a gap in compliance, we will take appropriate steps to remedy the situation, including changing our policies and practices if necessary.

7.  INFORMATION COLLECTED THROUGH TECHNOLOGY AND SOCIAL MEDIA

While  you visit our Website we may automatically collect information about your equipment and browsing history using cookies, server log files and other similar mechanisms. By using our Website, you consent to the use of cookies in accordance with this Privacy Policy.

A cookie is a small text file that is placed on your device when you visit a website and can last either for the duration of your visit (a “session cookie”) or for repeat visits (a “persistent cookie”). We use the word “cookie” in this Privacy Policy to refer to all files that collect information in this manner.

Some of the cookies we use may be necessary for security purposes, to authenticate you and enable you to use our Website. Other cookies may not be essential but may make it easier for you to use the Website (such as by identifying you, remembering your preferences and helping you navigate the Website). Some cookies are used to help us analyze the use and performance of the Website, as well as for advertising or tracking purposes, including allowing our advertising partners to track and analyze your behaviour on our Website and across the internet (e.g. Google Analytics, which tracks website usage and traffic.)

We collect the following types of information through cookies:

  • your IP address
  • your approximate geographic location
  • the type of operating system you are using (e.g., Windows or Mac)
  • the type of device you are using
  • the type of browser you are using
  • the domain name from which you reached our Website, which pages you visit on our Website, the frequency, date and time of your visits to our Website.

We may collect and may share this information with our Service Providers and agents for the purpose of understanding how visitors use our Website, to improve the functionality and content of the Website and to improve your interaction with the Website by making it easier for you to get back to the pages you have looked at the next time you visit. 

All major browsers allow you to disable cookies. If you do not want information collected through the use of cookies, you can disable cookies by changing the setting of your Internet browser. If you disable cookies, you may be unable to use or access some features on our Website.

Our Website may also provide links to third party websites. Clicking on those links may allow third parties to collect or share information about you. We cannot control these third party websites and we are not responsible for the actions or policies of such third parties. You should check the privacy policies of third parties when visiting their websites or when providing any Personal Information to them.

We may collect Personal Information when you interact with our content on third-party sites or platforms, such as Facebook, Instagram or You Tube. This may include data such as comments or feedback, “likes” or shares, profile data or the fact that you viewed or interacted with our content. If you voluntarily post or submit any information on these platforms, your Personal Information may be automatically included in the posting and may be collected and used by others.

8.  PROTECTING THE PRIVACY OF CHILDREN AND YOUTH

We understand that Personal Information relating to children and youth is particularly sensitive, especially the younger they are. Consistent with the position of the Office of the Privacy Commissioner of Canada, we will not knowingly collect Personal Information from children under the age of 18 unless we have the consent of their parents or guardians. We collect the minimum amount of Personal Information of children and youth necessary to achieve our purposes.

If you are a child or youth, you should review this Privacy Policy with your parents or guardians to make sure that you understand and consent to everything in it. IF YOU ARE UNDER THE AGE OF 18, you should not access our Website or provide us with any Personal Information unless your parent or guardian has consented. If we discover that we have collected Personal Information from a child under the AGE OF 18 without parental consent, we will delete that Personal Information.

9.  COMPLIANCE WITH CANADA’S ANTI-SPAM LEGISLATION

We comply with the requirements of Canada’s Anti-Spam Legislation, as amended from time to time at all times, including when: sending emails or texts from a Causable Inc. account, email address or domain name, obtaining consent from recipients to send emails or texts, managing and responding to requests to unsubscribe and documenting and retaining records of consent. Causable Inc.  does not send commercial electronic messages (“CEMs”) to any person unless it has express or implied consent from the recipient, the CEM includes identification and contact information for the sender and the CEM has an unsubscribe mechanism. To ensure compliance with CASL, Causable Inc. has adopted and implemented policies and procedures regarding CASL requirements and keeps records of consents and requests to unsubscribe. Complaints regarding the sending of CEMs and requests to unsubscribe from CEMs should be directed to the Privacy Officer.

10.  JURISDICTION 

Subject to this Privacy Policy,, your Personal Information may be disclosed in response to valid demands or requests from governments, regulators, courts and law enforcement authorities in Canada. Some or all of the Personal Information we collect may be transferred to third party Service Providers in the course of our normal operations or activities including, without limitation, being stored on servers in cloud-based environments or transferred through other technological measures to trusted third parties to assist us in serving you. As the case may be, some of our Service Providers may be located outside of Canada, Personal Information may be stored or processed in jurisdictions outside of Canada. As a result, this information may be subject to access requests from governments, courts, or law enforcement in those jurisdictions according to laws in those jurisdictions.

In addition, other jurisdictions, such as the European Union (“EU”) grant other rights with respect to Personal Information. If you reside in the EU, these rights include the rights to access your Personal Information; to have us erase it; to obtain and reuse it for your own purposes and to restrict its processing. Certain limitations on or exceptions to these rights may apply. If you are an EU resident, we may have to process or store your Personal Information outside of the EU. We use contracts with Service Providers and other mechanisms to protect your Personal Information in accordance with this Privacy Policy and applicable Canadian privacy law.

If you have any questions or concerns about our privacy practices or procedures in relation to other jurisdictions, or to exercise any of your rights under the applicable law of other jurisdictions, please contact the Privacy Officer. We will let you know if there are any limitations or exceptions that apply.