Inuvika Privacy Policy

 

Inuvika Inc and its subsidiary companies and affiliates (“Inuvika”) are committed to a policy of maintaining the privacy and security of your personal information which is information about an identifiable individual (as defined by applicable privacy or data protection laws).

 

This Privacy Policy explains Inuvika’s practices with respect to the processing of your personal information which includes the collection, use, processing, transfer, storage or disclosure of your personal information. In addition, agreements or notices associated with a particular Inuvika product, service, software or website (“Inuvika Offering”) may provide additional information about Inuvika’s processing of your personal information (“Notice”). The application of this Privacy Policy remains subject to applicable laws including legislation, regulations and the orders of any courts or other lawful authorities, other lawful requests or legal processes. Where applicable, the data controller in respect of your personal information is the Inuvika entity with whom you have entered into an agreement.

 

1. Inuvika’s purposes for using your personal information

 

When you use an Inuvika Offering, correspond with Inuvika, enter a contest sponsored by Inuvika or otherwise interact with Inuvika, Inuvika may process your personal information for the following purposes:

•  to understand and meet your needs and preferences, and to provide you with Inuvika Offerings, e.g.:

◦             for purposes related to the billing, activation, provision, maintenance, support, trouble shooting, resolving of disputes, deactivation, repair, refurbishment, replacement, upgrade or update of Inuvika Offerings;

◦             to ensure Inuvika Offerings are technically functioning as intended and to help identify and troubleshoot issues;

◦             to fulfill or enforce Notices applicable to a Inuvika Offering;

◦             to manage or respond to your inquiries;

•   to develop new and enhance existing Inuvika Offerings including to communicate with you about them using various means, e.g. to make available or send to you:

◦             upgrades or updates, or notices of upgrades or updates of Inuvika Offerings or third party content or related products, services and software;

◦             notices of promotions and upcoming events;

◦             to manage and develop our business and operations;

◦             to detect, monitor, investigate, mitigate or attempt to prevent fraud and technical or security issues or to protect Inuvika property;

◦             to allow for business continuity and disaster recovery operations;

◦             to enforce Inuvika’s legal rights;

◦             for statistical purposes;

•   to meet legal and regulatory requirements and to respond to emergency situations, e.g.:

◦             to respond to court orders, warrants or other lawful requests or legal processes;

◦             to provide emergency assistance in situations that may threaten the life or physical safety of you or others; or

 

•   for any other purposes for which you have consented, such as those that may be set out in Notices, and other purposes as permitted or required by any applicable law.

 

2. Your consent

 

Before using Inuvika Offerings, you may be required to agree to an applicable Notice that may contain additional information regarding Inuvika's processing of your personal information. Your agreement to the Notice or use of Inuvika Offerings indicates your consent for Inuvika to process your personal information for Inuvika's identified purposes.

 

a) When obtaining consent is not required

 

In certain circumstances, your personal information may be processed without your consent depending on the jurisdiction and any applicable laws. For example, Inuvika may not seek consent:

 

•    in the case of an emergency where the life, health or security of an individual may be threatened;

•    when legal, medical, or security reasons make it impossible or impractical to seek consent;

•    when information is necessary for the detection and prevention of fraud;

•    when disclosure is to a lawyer representing Inuvika;

•    to collect a debt;

•    to comply with a subpoena, warrant or other court order, lawful request or legal process; or

•    as may be otherwise required or permitted by law.

 

b) Children

 

Inuvika does not knowingly process personal information from individuals under the age of 13 without the consent of their parent or legal guardian.

 

c) Aggregated or anonymous information

 

Inuvika reserves the right to process, sell, trade or rent aggregated or anonymous information that is not associated with or linked to an identifiable individual.

 

3. Types of information processed

 

The types of information that Inuvika may process can vary. For example:

 

a) Account and membership information: Information processed could include your name, postal address, email address, telephone number, portal entries, communications with Inuvika and any recorded complaints. Inuvika may also process your account credentials, passwords, profile information and other information you provide to facilitate the Inuvika Offerings you use.

 

b) Cookies or similar technologies: A cookie is a small text file or piece of data that is downloaded to and stored on your computer or device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognizes the cookie. As part of Inuvika's Offerings, Inuvika may use different types of cookies or similar technologies ("Cookies") from time to time. Certain Cookies are necessary to facilitate your use of Inuvika Offerings or to protect both you and Inuvika when you sign-in to certain services (such as our partner portal to make it easier whenever you want to use Inuvika Offerings or to confirm that you are logged in). Other Cookies are more performance-related such as for analytics or contextual purposes to help us understand how users engage with Inuvika Offerings so we can provide new and enhanced Inuvika Offerings (such as which pages or features are most popular). Some Cookies are more function-related and help personalize your experience and make Inuvika Offerings easier to use (such as your language or jurisdiction preferences), or to help Inuvika display personalized content to you. Other Cookies or similar technologies may be used for targeted advertising purposes (e.g. certain Inuvika Offerings may be supported by advertising revenue and display advertisements and promotions which may be targeted against non-personally identifiable attributes or aggregate data collected by Inuvika, and Inuvika or our service providers may place such advertising on Inuvika Offerings). Anonymized or aggregated information about usage of Inuvika Offerings may be provided in a form that does not personally identify you to our service providers as part of analytics services and to help manage online advertising. Most browsers are initially set to accept Cookies, but you can usually change your browser settings to refuse Cookies or to indicate when a Cookie is being sent. You can typically remove or block browser Cookies using the settings in your browser, but that may impact your ability to use certain Inuvika Offerings as they may not work well or at all with Cookies disabled. Choosing to continue without disabling Cookies indicates your consent to Inuvika's use of Cookies in accordance with this Privacy Policy. Please visit the section below on "Managing your preferences" for more information on managing Inuvika's use of Cookies.

 

c) Financial information: If you purchase a product, service, software or customer support directly from Inuvika or our partners, Inuvika may process credit card or other payment information and use it to facilitate billing and credit services and conduct credit checks, as applicable.

 

d) Quality assurance and customer service: Your customer service telephone calls with Inuvika and Inuvika's partners may be recorded or monitored for quality assurance and customer service purposes such as to assist in addressing your inquiries, troubleshooting, training and analytics to identify trends and make improvements to Inuvika Offerings.

 

e) Third party information: If necessary to fulfill Inuvika's identified purposes, Inuvika may combine the information you submit to Inuvika with information obtained from other sources or Third Party Offerings. For example, Inuvika may receive personal information about you from third parties involved in providing you with the products, services, and software you are utilizing, such as from our partners. Inuvika treats all such personal information in accordance with this Privacy Policy and the terms and conditions between Inuvika and such third parties, if any, may also apply. However, the third party's own use of your personal information in such cases will be determined by your agreement(s) with the third party.

Some of this information would not by itself identify you to Inuvika or be personally identifiable and is therefore considered non-personal information. If Inuvika combines any such non-personal information with other personal information available to Inuvika, the combined information will be treated as personal information in accordance with this Privacy Policy.

 

4. Inuvika's processing of your personal information

 

a) Retention

 

Inuvika retains personal information as long as necessary for the fulfillment of Inuvika's identified purposes or as otherwise necessary to comply with applicable laws. When personal information is no longer necessary or relevant for Inuvika's identified purposes, or required by applicable laws, Inuvika will take steps to have it deleted, destroyed, erased, aggregated or made anonymous. Consistent with good business practice, Inuvika continues to evolve our controls, schedules and practices for information and records retention and destruction which apply to your personal information.

 

b) International operations and onward transfers

 

Inuvika has an international presence, with offices and facilities in multiple jurisdictions. All of Inuvika's international operations are subject to this Privacy Policy.

 

You agree that, to be able to better serve you and facilitate the use or functioning of Inuvika Offerings, your personal information may be collected, used, processed, transferred or stored by or on behalf of Inuvika in multiple jurisdictions including Canada, the United States, the European Economic Area and any other country where Inuvika or our service providers have offices or facilities, including countries which may be outside the region in which you are situated and may have different privacy or data protection legislation, and may therefore be subject to the laws of these countries. If you are a resident of the European Economic Area or a country which restricts data transfers outside of that jurisdiction or region without your consent, you consent to your personal information being transferred outside of the European Economic Area or your country for processing or storage by or on behalf of Inuvika.

 

Given the international nature of our business, Inuvika may also be required to disclose or otherwise provide access to your communications data, including the contents of your communications, and other information under the laws of countries where Inuvika, our service providers, affiliates and data are located. By using Inuvika Offerings, you consent to our compliance with applicable laws including any legal process that Inuvika believes requires that we produce or provide access to your communications data and other information.

 

c) Marketing communications from Inuvika

 

Inuvika may communicate with you by a variety of means, such as using the email address(es) that you provide us through communication with us, free trial offers or signing up for newsletters or other ongoing communications. Inuvika may communicate information, surveys, marketing materials, advertisements or customized content which has been personalized to try to make it more relevant to you as part of your existing business relationship with Inuvika. For example, we may do so where you have not unsubscribed from receiving such communications and it is permitted by law, where you have explicitly agreed to receive such communications, where you use free services which rely upon advertising (including targeted advertising based on profile information), or through utilizing aggregated data or data that has been made anonymous. Inuvika may ask you from time to time if you would like to receive from Inuvika or authorized third parties selected by Inuvika additional announcements, news, offers or event invitations regarding Inuvika and Inuvika Offerings. You may also choose to provide Inuvika with information in response to various Inuvika promotions. If you agree to participate in contests, surveys, giveaways, reviews, or other promotions that Inuvika sponsors or co-sponsors, please ensure that you read the Notice that may be associated with these initiatives in order to obtain further details about how your personal information will be managed. Typically, an unsubscribe mechanism is included with every Inuvika marketing or commercial communication. Please visit the section below on "Managing your preferences" for more information on managing marketing or commercial communications from Inuvika.

 

d) Service-related communications from Inuvika

 

Inuvika may also send you certain service-related communications. For example, Inuvika may send a welcome email or message when you first start using an Inuvika Offering, to notify you of important changes, to tell you how to manage your credentials or account, to provide maintenance and support notifications or information about upgrades or updates, to provide warranty information, recall information, safety or security information, or for surveys of current or former users. Because such service-related communications are important to your use of Inuvika Offerings, you may not opt-out of receiving these communications.

 

e) Information sharing

 

In accordance with this Privacy Policy, Inuvika may share your personal information within Inuvika or with a partner servicing the region where you are located. Inuvika may also share information with our financial, insurance, legal, accounting or other advisors that provide professional services to Inuvika. Inuvika may also share information in a manner consistent with this Privacy Policy with third parties involved in providing Inuvika Offerings to you including authorized resellers, distributors, hosting providers and hardware resellers.

 

It is Inuvika's policy to enter into confidentiality obligations with any third party that obtains confidential information including personal information from Inuvika. For example, except where Inuvika is required or permitted by law to disclose personal information, our partners to whom we provide your personal information typically agree to hold the information in confidence and only use the information for the purposes for which it was provided or to comply with applicable laws.

 

In the event of the sale of all or a portion of Inuvika's assets, Inuvika may provide personal information to the third party purchaser.

 

Inuvika may utilize third parties (e.g. advertising networks) to target advertisements at non-personally identifiable attributes or aggregated data that is derived from profile data processed by Inuvika, and provide such third parties with general statistics relating to the advertisements delivered. Please visit the section below on "Managing your preferences" for more information on managing marketing or commercial communications from Inuvika.

 

5. Accuracy of your personal information

 

Inuvika takes reasonable steps to ensure that personal information is sufficiently accurate, complete and up-to-date. Inuvika also depends on you to update or correct your personal information whenever necessary.

 

6. Safeguarding your personal information

 

Inuvika continues to evolve our physical, organizational and technological measures used to protect your personal information against loss or theft, unauthorized access, alteration or disclosure appropriate to its level of sensitivity.. Inuvika employees are made aware of the importance of appropriately and securely handling personal information, to keep it in secure locations and systems, and to limit access to personal information to those with a need to know it for business reasons.

 

a) Your obligations to safeguard your personal information

 

You also have an obligation to safeguard your personal information. You can reduce risk of unauthorized access to your personal information by using common sense security practices. For example, you are responsible for utilizing appropriate security measures to control access to your devices and cloud, such as creating a strong password that cannot be easily guessed by others (e.g. by including punctuation marks, numbers, capital and lowercase letters, and choosing a password of an appropriate length and which does not include your name or account name), using different passwords for different services and using up-to-date antivirus software.

 

7. You can access your personal information

 

Upon written request, Inuvika will inform you whether or not it holds personal information about you and provide you with access to your information within a reasonable timeframe and at minimal cost in accordance with applicable laws. If you identify an inaccuracy or incompleteness in your personal information, Inuvika will amend your information and notify any third parties as required by applicable laws.

 

In certain situations and depending on applicable laws, Inuvika may not be able to provide access to all of the personal information that it holds about you. For example, Inuvika may not provide access to information if doing so:

•    would likely reveal personal information about a third party;

•    could reasonably be expected to threaten the life or security of another individual;

•    would reveal Inuvika or third party confidential information;

•    includes information that is protected by solicitor or attorney client privilege; or

•    includes information that was processed in relation to the investigation of a breach of an agreement or a contravention of a law.

In order to safeguard your personal information from unauthorized access, Inuvika may ask that you provide sufficient information to identify yourself prior to providing access to your personal information.

 

Depending on the circumstances and applicable laws, Inuvika may refuse to process certain access requests (e.g. access requests that are unreasonably repetitive or systematic, would be extremely impractical or require disproportionate technical effort).

 

 

8. Questions or concerns? How to contact us

 

Inuvika welcomes your questions or comments regarding this Privacy Policy and the way we process your personal information. If you have any questions, concerns or wish to request access to your personal information pursuant to applicable privacy or data protection laws, please contact Inuvika either by email or in writing and we will use commercially reasonable efforts to respond:

 

•  by email info@inuvika.com, or

•  write to Inuvika:

 

Inuvika Privacy Office

Inuvika Inc.

1 Toronto Street,

Suite 910, PO Box 28,

Toronto, ON, Canada,

M5V 4A2

 

a)            Managing your preferences

 

Generally, you may withdraw at any time your consent for Inuvika to process your personal information in accordance with this Privacy Policy, subject to legal or contractual restrictions and reasonable notice. For example, although you can use Inuvika Offerings for some purposes without providing us with any personal information, Inuvika may need to process personal information for some services, including those that require payment or involve an ongoing relationship such as registration or subscription services. As such, Inuvika may continue to use your personal information as may be required to provide you with requested services, and to the extent that Inuvika is contractually obligated to do so or as necessary to enforce any contractual obligations you may have with Inuvika. If you refuse to provide Inuvika with the information it requires or later contact us in writing at the addresses above to withdraw your consent to use and disclose this information, Inuvika may no longer be able to provide you with your Inuvika Offerings.

 

Marketing or commercial communications: You may unsubscribe from receiving marketing or commercial communications about Inuvika products, services and software by:

•        clicking the unsubscribe link at the end of any marketing or commercial communication from Inuvika;

•        by writing to Inuvika Privacy Office at the address above and advising what particular types of marketing or commercial communications you no longer wish to receive.

 

Cookies: As noted above, you may also opt-out of Inuvika's use of Cookies through one of the following methods:

 

•        Change your browser settings to refuse Cookies or to indicate when a Cookie is being sent.

•        Remove or block browser Cookies using the settings in your browser, but that may impact your ability to use certain Inuvika Offerings as they may not work well or at all with Cookies disabled.

 

b)            Changes to this Privacy Policy

 

Inuvika will occasionally update this Privacy Policy so that it remains relevant and current with changing technologies, applicable laws, our evolving business practices and the needs of our users. Inuvika encourages you to periodically review this Privacy Policy to stay informed of how Inuvika manages your personal information. If any changes are made to this Privacy Policy, Inuvika will revise the "Last Updated" date that is indicated on the Privacy Policy.

 

Last Updated 2017-01