Last updated: February 10, 2021
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This Policy describes our practices with respect to how we may collect, use, disclose, retain, dispose and otherwise process (collectively, “process”) and how you may correct, update and access your personal information that you provide as a user of (a) our software applications “Source”, “Reach”, “Drive” and such other software applications as may be made available by us from time to time (collectively, the “Applications”), (b) our websites located at www.icthrive.com, www.reach.team (collectively, the “Websites”) and (c) the services we provide through the Application or the Websites (collectively, the “Services”).
Our Applications and Websites may contain links or direct you to other websites, software, service providers or Internet resources (the “Other Providers”) which are provided solely for your convenience, benefit and information. When you click on such links, you are contacting another website, software, service provider or Internet resource. We are not responsible nor liable for, nor have control over those Other Providers or how they process your personal information. We encourage you to read the privacy policies of such Other Providers to learn how they process your personal information.
Information that we collect from you
For the purposes of this Policy, “personal information” means any identifiable information about an individual, such as an individual’s name, home address, telephone number, or email address.
When you use our Services, we may collect the following personal information from you:
- Contact information such as name, email address, mailing address, and phone number;
- Demographic information such as location of residence;
- Billing information such as credit card number and billing address; and
- Usage data such as:
- Information about the device used to access our Service;
- Destination of hyperlinks in order to uniquely track them; or
- Other anonymous identifiers or cookies may be sent to your devices and may be used when you interact with our Services.
Your personal information may be collected when:
- You provide your information to use through a submission form;
- You register for an account with us;
- You connect with us through a submission form, email, or social media;
- You link a third-party application or account, like Office 365, to our Services;
- We collect cookies and other tracking information through your use of our Websites; or
- We collect data from third parties or publicly available sources.
We do not knowingly collect your personal information from any third parties unless you consent or we are otherwise exempted, required or permitted by applicable laws to do so. If we collect your personal information from a third party, we will only process that information for the specific purpose for which it was provided to us in accordance with this Policy and the policy under which that information was collected.
We only collect personal information that we need to provide the Service. We encourage you to not provide us with any personal information beyond what is necessary and as requested by us.
To ensure the Service is optimized for your use and for future communications between us, we may save your user data in the form of cookies or log files and use such cookies or log files to collect standard Internet log information about how and when you use our Service. This information may include, but not be limited to, your IP address and location data, weblogs, time zone, date, your language preferences, browsers used, web addressees visited, other communication data, searches conducted, pages visited.
Some elements of our Service are delivered by third-parties, which may collect information about your use of our Service. In doing so, these third-parties may place or recognize cookies, web beacons, or other log files to track the types of information noted above.
For example, in the course of serving certain advertisements, an advertiser may place or recognize a unique cookie on your device in order to collect certain information about your use of our Services. For another example, an advertiser or ad server may also be able to collect your device’s unique identifier in the course of serving an ad. In many cases, this information could be used to show you ads on other websites based on your interests.
You can manage your cookie preferences, but please note that if you refuse to allow cookies, you may not be able to use certain features of our Service.
In order to provide and improve the Service, we use Google Analytics to better understand how and when you use the Service. In doing so, we store a cookie on your computer and Google reads these cookies and may serve you ads for our Service or other services on a third-party website, after you have visited our Service.
The security of your personal information is important to us. We store and secure information we collect using security standards, restricting the access to this data to specific services via network security. We insist that our personnel and those of our providers only access and use personal information on a “need to know” basis to properly perform those duties, and even then only to the strict extent necessary to perform them.
However, no method of transmission over the Internet, or method of electronic storage, is completely secure. As such, despite our safeguards and protocols, we cannot fully guarantee the security of your personal information and you should always exercise caution when disclosing personal information over the Internet.
The reasons why we process your personal information
We may process your personal information for the following purposes (the “Purposes”):
- To verify and authenticate your identity;
- To connect with us through social media;
- To ensure that the our Services are optimized for your use and benefit;
- To operate, maintain and provide to you the Services, including the features and functionality of our Websites and Applications;
- To communicate with you to provide you services, contacts, materials and/or recommendations for your needs as identified by you through phone, email, or the Service;
- To carry out our obligations arising from any contracts entered into between you and us;
- To comply with internal policies and procedures and other legal, accounting, or security requirements; or
- To share your personal information with our employees, contractors, consultants and other third party service providers such as web hosting providers, advertising agencies, payment processors or customer service agencies (“Third Party Processors”) who require this information to assist us with establishing, maintaining and managing our relationship with you and optimizing and providing the Services for your use and benefit.
We will only process your personal information for the Purpose(s) for which we intend to process such information. Otherwise, we will not process your personal information without your consent.
When we disclose your personal information
We may disclose your personal information for the Purposes as described in this Policy in the following ways:
- To our employees and contractors;
- To our business partners;
- To our service providers including web hosting providers, advertising agencies, payment processors and customer service agencies; and
- As required by law, to law enforcement, government or regulatory bodies, or other lawful authorities.
Your personal information that we collect may be processed in the United States or elsewhere outside of Canada. As a result, your personal information may be accessible to law enforcement and regulatory authorities in accordance with the USA PATRIOT Act, the USA Freedom Act and other applicable laws of the United States or elsewhere.
Our legal bases for processing your personal information
We will process your personal information only with your knowledge and consent, except where exempted, required or permitted by applicable laws. The form of consent may vary depending on the circumstances and the type of information being requested. Your consent may be express with clear options to say “yes” or “no”, such as by being asked to check a box to indicate your consent, or implied, such as when you provide us with your address through a form or email seeking information and we use those means to respond to your request. Your consent can also be provided by an authorized representative. Taking into account the sensitivity of your personal information, purposes of collection, and your reasonable expectations, we will obtain the form of consent that is appropriate to the
personal information being processed. By using our Websites, Applications, or Service, or otherwise by choosing to provide us with your personal information, you acknowledge and consent to the processing of your personal information in accordance with this Policy and as may be further identified when the personal information is collected. When we process your personal information for a new purpose, we will document that new purpose and ask for your consent again.
If you do not consent to the processing of your personal information in accordance with this Policy, please do not access or continue to use any of our Websites, Applications or Services or otherwise provide any personal information to us.
You may refuse to provide consent or may notify us at any time that you wish to withdraw or change your consent to the processing of your personal information without penalty, subject to legal or contractual restrictions and reasonable notice by (i) changing your privacy preferences through the Websites or Applications, (ii) deleting your account with the Websites or Applications and stopping use of the Websites or Applications, or (iii) opting out of the use of your personal information such as unsubscribing to any newsletter or mailing list subscription that we provide through the Websites or Applications. However, if you withdraw or change your consent, we may not be able to provide you with our Services.
Aside from consent, we may also process your personal information under other legal bases, as permitted by applicable law.
Requests for access to and correction of personal information
Applicable privacy laws allow, to varying degrees, individuals the right to access and request the correction of errors or omissions in his or her personal information that is in our custody or under our control. Our privacy team will assist you with such an access request. This includes:
- your personal information under our custody or control;
- how your personal information under our control may be or has been used by us; and
- names of any individuals and organizations to which your personal information has been disclosed.
We will respond to requests within the time allowed by applicable privacy laws and will make every effort to respond as accurately and completely as possible. Any corrections made to personal information will be promptly sent to any organization it was disclosed to.
In certain exceptional circumstances, we may not be able to provide access to certain personal information we hold about an individual. If access cannot be provided, we will notify the individual making the request within 30 days, in writing, of the reasons for the refusal.
Retention of your personal information
We keep your information only for as long as we need it for legitimate business purposes and compliance with legal requirements. We ensure that our retention standards meet these parameters by either anonymizing, destroying or erasing your personal information once we no longer need your personal information, or once the required retention period passes. If we do not destroy or erase your information, we will remove any personally identifiable information so that it becomes anonymous.
We are committed to compliance with Canada’s Anti-Spam Legislation (“CASL”). Any electronic communication we send to outside parties is protected by a range of business procedures, processes and policies to ensure that such communication is done in compliance with CASL. In our electronic communications with outside parties, we comply with the rules established by CASL and enforced by various Canadian authorities including the Canadian Radio-television and Telecommunications Commission. CASL regulates, and our policies generally apply to, each commercial electronic message we send (a “CEM”) we send. A CEM is an electronic message sent to an electronic address that, among its purposes, encourages participation in a commercial activity.
In addition to adopting this Policy, we undertook various initiatives out of transparency to ensure we comply with CASL, which include:
- Consent— we do not send you CEMs without your consent. This consent typically must be “express” (expressly acknowledged by you), but in certain circumstances can be “implied”. We created our sign-up, registration and consent forms in order to ensure that your consent is meaningful (i.e. informed and freely given) in accordance with CASL. When we collect your electronic contact information, you will know the exact purposes behind the collection.
- Content— we adopted processes to ensure that our CEMs contain the following content prescribed under CASL, which will usually be in the footer of the CEM. We will:
- identify ourselves as the party sending the CEM, and whether we are sending the message on our own behalf or on behalf of someone else;
- provide you with our contact information; and
- set out a clear, working unsubscribe mechanism or preference centre that is easy to use, automatic, and at no cost to you (other than your own cost of connecting to the Internet).
- Clarity— we ensured that each aspect of a CEM, including its header, content, or any links or URLs in the CEM) conveys the appropriate information, whether viewed individually or taken as a whole, so that you always know what you are clicking on.
If you receive a CEM from us but believe that you should not have or no longer wish to receive CEMs, we will aim to respect your preferences in a timely manner once you update them through our unsubscribe mechanism. CASL requires us to process unsubscribe requests within 10 business days. If you have any questions or concerns about our unsubscribe options, you may contact us at the address indicated below.
We want to hear from you
We encourage you to contact us directly as this will ensure your email does not get caught by our spam-filter. We have a number of forms on our site for you to request more information about IC Thrive, including how we handle your personal information, demo requests, white paper and ebook downloads and subscription forms.
If you prefer to contact us through alternative means, you can contact our privacy team at firstname.lastname@example.org or give us a call at 1-844-924-9770 (toll free in North America) or 604-924-9770 (outside North America). Please do not hesitate to get in contact with us if you have any questions about this Policy.
You will find the date of the latest update at the end of this Policy. We encourage you to periodically review this page for the latest information on our privacy practices to ensure you are aware of any changes. Your continued use of the Service signifies your acceptance of any changes to this Policy.