1. About Your Privacy
(1) At ACTO Technologies Inc. (“ACTO”), your privacy is, and always has been, very important to us. We are dedicated to providing you with superior digital products and content while protecting your privacy and safeguarding your personal information.
(2) “Personal Information” is defined in Canada’s Personal Information Protection and Electronic Documents Act, S.C. 2000, c. 5 (“PIPEDA”), as information about an identifiable individual, though it does not include the name, business title, business address or telephone number of employees of organizations.
(3) We take your privacy seriously and, when you (or any authorized user) provide us with any personal information, we endeavour to keep it safe. We will not share your personal information with third parties and will take all reasonable precautions to protect it.
2. Our Ten Privacy Principles
(1) ACTO is committed to maintaining the accuracy, confidentiality and security of your personal information. As part of this commitment, ACTO has adopted the following ten principles, based on the values set by the Canadian Standards Association’s Model Code for the Protection of Personal Information and Canada’s PIPEDA.
(a) Accountability: ACTO is responsible for maintaining and protecting the personal information under its control and shall designate one or more individuals to be accountable for that company’s compliance with these principles.
(b) Identifying Purposes: The purposes for which personal information is collected shall be identified before or at the time the personal information is collected.
(c) Consent: Individual’s consent will be obtained for the collection, use or disclosure of personal information, except where the law provides an exemption.
(d) Limiting Collection: The personal information we collect shall be limited only to that which is necessary for the purposes identified.
(e) Limiting Use, Disclosure and Retention: Personal information shall only be used or disclosed for the purposes for which it was collected, unless an individual has otherwise consented or when it is required or permitted by law. Personal information shall be retained only as long as necessary for the fulfillment of those purposes.
(f) Accuracy: We shall keep personal information as accurate, complete and up-to-date as may be necessary to fulfill the purposes for which it is to be used.
(g) Safeguards: We shall protect personal information using security safeguards that are appropriate to the sensitivity level of the personal information received.
(h) Openness: ACTO will provide information to individuals about our policies and procedures relating to the management of personal information that is under our control.
(i) Individual’s Access: On written request to our Chief Technology Officer, an individual will be informed of the existence, use and disclosure of their personal information that is under our control, and may be given access to that personal information as required and permitted by law. Individuals are entitled to challenge the accuracy and completeness of that personal information and request that it be amended, if appropriate.
(j) Handling Enquiries or Complaints: Any questions or enquiries concerning compliance with our privacy policies and procedures may be addressed to our Chief Technology Officer, as set out below.
3. Why We Collect and Use Personal Information
(1) Collecting personal information about you is essential to our being able to provide the products and services that best meet the needs of both yourself and/ or authorized third parties (“Client”). While the personal information we collect may come directly from you, it may also be provided by our affiliates or other third parties (such as employers, insurance companies, insurance brokers or agents, credit organizations, motor vehicle and driver licensing authorities, financial institutions, medical professionals, etc.).
(2) Personal information may be used:
(a) to determine eligibility for products and services;
(b) to process applications for Clients, and provide requested information, products or services;
(c) to understand and assess Clients’ ongoing needs and offer products and services to meet those needs;
(d) for billing and accounting services relating to our products and services:
(e) for Client communication, service and administration;
(f) for claims administration;
(g) for internal, external and regulatory audit purposes;
(h) to comply with legal and regulatory requirements; or
(i) to share or exchange reports and information with credit reporting agencies, credit bureaus, and any other person, corporation, firm or enterprise to verify the accuracy of personal information.
(3) Personal information may also be used for other purposes, subject to obtaining your prior consent for such use.
4. Consent To Use Personal Information
(1) Consent may be obtained in various ways. We may obtain your express consent or we may determine that consent has been implied by the circumstances. Express consent could be in writing (for example in a signed consent, e-mail or application form), or verbally in person or over the telephone. When we receive personal information from you that enables us to provide you with a requested product or service, your consent to allow us to deal with that personal information in a reasonable manner would be implied. If you need to provide personal information about other individuals (such as employees, dependents, etc.), you must first obtain their consent for these purposes prior to your disclosure to us.
(2) Providing us with your personal information is always your choice. When you request services from us, we ask that you provide information that enables us to respond to your request. In doing so, you consent to our collection, use and disclosure to appropriate third parties of such personal information for these purposes. You also authorize us to use and retain this personal information for as long as it may be required for the purposes described above. Your consent remains valid even after the termination of our relationship with you, unless you provide us with written notice that such consent is withdrawn. By withdrawing your consent, or not providing it in the first place, you may limit or even prevent us from being able to provide you or an authorized third party (such as an employer) with the products or services desired.
(3) In certain circumstances, consent cannot be withdrawn, such as where personal information is required for policy issuance or renewal, insurance underwriting or claims administration of current policies. There are also legal exceptions where we will not need to obtain consent or explain the purposes for the collection, use or disclosure of personal information. For example, this exception would apply if there is an emergency that threatens the life, health or security of an individual, or if we must comply with a court order.
5. Sharing Personal Information With Others
(1) We are not in the business of selling client lists or personal information to others. In providing our services, we may need to disclose the personal information we collect to affiliates, subsidiaries, successors and other service providers or agents who perform various functions for us (such as content creators).
(2) As ACTO continues to develop and grow, we may buy or sell parts of a business. As our businesses consist primarily of client relationships, information regarding the particular accounts or services being purchased or sold could include personal information and be one of the transferred business assets.
(3) In certain circumstances, we may be required to provide personal information to third parties for legal or regulatory purposes.
(4) We may also use this personal information to assess your future needs and to offer the products and services that may best meet those needs, from ourselves, our affiliates or reputable organizations selected by us. If you do not wish to receive these offers or such information, please contact our Chief Technology Officer as outlined below in the contact information section.
6. Keeping Information Accurate
(1) It is important that your personal information is accurate and complete. Having accurate information about you enables us to give you the best possible service. You have the right to access, verify and amend the information we have about you. We rely on you to keep us informed of any changes, such as a change of address, telephone number or any other circumstances – simply contact your local office representative.
(2) Despite our best efforts, errors sometimes do occur. If you identify any personal information that is out-of-date, incorrect or incomplete, let us know and we will make the corrections promptly and use every reasonable effort to communicate these changes to other parties who may have inadvertently received incorrect or out-of-date personal information from us.
7. How We Safeguard Personal Information
(1) At ACTO, we employ physical, electronic and procedural safeguards to protect our systems and all personal information under our control against unauthorized access and use. All safety and security measures are appropriate to the sensitivity level of the information collected.
(2) Our service providers and agents are required to maintain Client confidentiality, and may not use the information for any unauthorized purpose.
(3) Employees are governed by strict standards and policies to ensure that personal information is secure and treated with the utmost care and respect.
8. Privacy and Information Collection
(1) ACTO may collect user information from its mobile applications (for example, through embedded analytical scripts), Web sites (for example, via cookies which are alphanumeric identifiers transmitted from a Web site to a visitor’s browser and IP address) or any other digital product it offers. This information is used solely for enabling us to provide you with a customized user experience and to find ways to improve our digital product offerings. In some instances, it may be possible to disable cookies via your browser settings or disable analytics or tracking capabilities through device or application settings. However, in so doing, some Web sites, mobile applications, or other digital products may not function properly or optimally.
(3) Tracking and Error Reporting: To help us understand how we can make ACTO Suite better for you, we use a tracking code provided by Crashalytics in our mobile and web applications that generates and transmits an error report in case of an error. The information contained in an error report is anonymous and does not provide us with identifiable information, but helps us improve our product and ensure that our support pages answer all of the most popular questions correctly.
(4) Providing User Support: Intercom is a customer support and communication application that creates customer support tickets and enables two way communication between users of the ACTO platform and ACTO support infrastructure. In order to provide users with support and resolve any technical issues they may have, Intercom identifies users and provides this information to ACTO. We also use Intercom to send our email newsletters that contain, among other things, information about product updates, success stories, and upcoming product releases. You can opt out of these emails by sending an unsubscribe request to email@example.com
9. Contact Information
Please contact our Chief Technology Officer to obtain further information about our policies and procedures or if you have any unresolved enquiries or concerns. Our Chief Technology Officer can be contacted as follows:
Mail: 200-121 Richmond St W
Toronto, Ontario M5H 2K1
Attention: Chief Technology Officer (Kumar Erramilli)