This privacy policy (this “Policy”) describes the practices of SimpliCity Digital Inc. and its corporate affiliates and digital products ("SimpliCity", “we”, “us”, “our”) with respect to our collection, use, storage and disclosure of personal information provided to us from users of:
(a) the website operated at getsimplicity.ca, simplicitycms.ca, and such other locations as made available from time to time (the “Website”),
(b) any “app” or other front-end software provided by us (for greater certainty, excluding third party software that may interact with the Website or the Service, as defined below) that interacts or interfaces with the Website (the “Software”), and
(c) the services we provide through the Website and/or the Software (collectively, the “Service”).
It also describes the choices available to you regarding our use of your personal information and how you can access and update this information. This Policy is incorporated by reference to our general Terms of Use, and forms an integral part of it. All capitalized terms not otherwise defined herein have the meaning provided in our Terms of Use.
We respect and uphold individual rights to privacy and the protection of personal information. We know how important it is to protect your personal information and want to make every customer experience safe and secure. In-keeping with that goal, we have developed this Policy to explain our practices for the collection, use, and disclosure of your personal information. We have appointed a Privacy Officer who is responsible for our compliance with this Policy. Information on how to contact the Privacy Officer can be found below.
For the purposes of this Policy, “personal information” means information about an identifiable individual, including, for example, an individual’s name, home address, telephone number, sex, income and family status. Personal information does not include information that would enable an individual to be contacted at a place of business, for example an employee’s name, position or title, business telephone number, or business address. We will only collect, use or disclose personal information in accordance with this Policy, or in accordance with laws applicable to the collection, use and disclosure of your personal information by us (“Applicable Privacy Laws”).
On the other hand, “non-personal information” is any type of information other than personal information, and is excluded from this Policy. For example, non-personal information would include business information, or information that enables an individual to be contacted at a place of business, for example an employee’s name, position or title, business email, business telephone number, or business address. Non-personal information also includes information that is anonymous or not about an identifiable person, such as web browsing information (e.g. the domain used to access the Website, or the type and version of device, browser or operating system being used to access the Service), or aggregate information that anonymizes the underlying data (like the number of visitors, what pages users visit, average time spent on the Website or on various parts of the Service). We will collect, use or disclose non-personal information in accordance with our ordinary business practices, but always in accordance with any applicable laws. This Policy, however, only covers our collection, use and disclosure of personal information.
This site is intended solely for users at least 18 years of age (or the age of majority in your jurisdiction) or older. We do not knowingly collect personal information about any person under the age of majority (usually the age of 18 or 19, but it varies in different jurisdictions), and no such person, nor any parent or guardian as it relates to such person, should submit their personal information to us for any reason. Please do not submit personal information about minors to us, whether through the Website, the Service or otherwise.
We have appointed a Privacy Officer who is responsible for our compliance with this Policy. Information on how to contact the Privacy Officer can be found below.
As indicated above, we collect two types of information through our Service: personal information and non-personal information. The types of information we collect about you will depend on the nature of your interaction with us or the Service.
We may collect the following personal information from you:
For our own research purposes, we may link tracking information (see below) with personal information voluntarily provided by Website users. Once such a link is made, all of the linked information is treated as personal information and will be used and disclosed only in accordance with this Policy.
We may also automatically gather information about the device you use to access the Website or Services, such as your IP address, browser/device type, referring/exit pages, operating system, as well as which aspects of our performance metric indicators available with our technology or our licensees’ products you prefer using. Some of this may be personal information, but in typical cases it is non-personal information. Specific examples follow:
We may use your personal information, in combination with your non-personal information, for a variety of business purposes, for example to:
We will not sell or trade your personal information to third parties.
We will collect, use, or disclose your personal information only with your knowledge and consent, except where required or permitted by Applicable Privacy Laws. When you choose to provide us with your personal information you consent to the use of your personal information as identified in this Policy and as may be further identified at the time of collection.
Sometimes you will be asked to give your express consent to our collection, use or disclosure of personal information – for example, by being asked to check a box to indicate your consent to receive marketing communications in compliance with Canada’s anti-spam laws.
Other times, you may provide your implied consent to our collection, use or disclosure of personal information when we can reasonably conclude that you have given consent by some action you have taken or an action you have decided not to take. Generally, this occurs where the purpose for the use of your personal information would be reasonably apparent to you – for example, when you provide us with your address through a form or email seeking information, you provide us with implied consent to use that address in order to respond to your request.
Other times, you may provide your implied consent to our collection, use or disclosure of personal information when we can reasonably conclude that you have given consent by some action you have taken or an action you have decided not to take. Generally, this occurs where the purpose for the use of your personal information would be reasonably apparent to you – for example, when you provide us with your address through a form or email seeking information, you provide us with implied consent to use that address in order to respond to your request.
If you provide us personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us and in accordance with this Policy and such policy under which that information was collected.
We will share your personal information with third parties only in the ways that are described in this Policy. We will not sell your personal information to third parties, however the use of our Service necessarily requires some sharing or disclosure of your personal information. Some of these activities may result in personal information collected by us being stored or processed in the United States or elsewhere outside of Canada and, 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.
We may provide your personal information to companies that provide services to help us with the Service such as web hosting providers, payment processors, and customer service agencies (“Third Party Processors”). These Third Party Processors are authorized to use your personal information only as necessary to provide these services to us, and in a manner consistent with this Policy. To the best of our ability, we have selected Third Party Processors who will only use your information in compliance with this Policy, but they may have their own specific policies regarding the collection, use and personal information. We will use commercially reasonable efforts to identify such Third Party Processors when we are collecting your personal information.
We may also disclose your personal information (i) as required by law such as to comply with a subpoena, or similar legal process, (ii) when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request, or (iii) to any other third party with your prior consent to do so.
Our Service may contain links to other websites or Internet resources which are provided solely for your convenience and information. When you click on one of those links you are contacting another website or Internet resource. We have no responsibility or liability for, or control over, those other websites or Internet resources or their collection, use and disclosure of your personal information. We encourage you to read the privacy policies of those other websites to learn how they collect and use your personal information.
The security of your personal information is important to us. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. We employ physical, administrative, contractual and technological safeguards to protect personal information, and insist that our service providers do the same. We insist that our personnel, and those of our providers, only access and use personal information in order to properly perform those duties, and even then only to the strict extent necessary to perform them.
We follow generally accepted industry standards to protect personal information submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure, and so you should always exercise caution when disclosing sensitive information over the Internet. Remember, if you have any questions about security on our Website, you can always contact us at info@simplicitycms.ca.
Applicable Privacy Laws allow, to varying degrees, individuals the right to access and/or request the correction of errors or omissions in their personal information that is in our custody or under our control. Our Privacy Officer will assist you with such an access request. This includes:
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 that 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.
We are committed to compliance with the law known as Canada’s Anti-Spam Legislation (“CASL”). Any electronic communication sent by us 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”), which 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, and to provide transparency about our compliance, we have undertaken various initiatives in order to ensure we are compliant with CASL in various respects:
If you have received a CEM from us, and you believe that you should not have or you do not wish to receive them (even if we are allowed to send them), we will endeavour to respect your inbox preferences. Without limiting our legal rights or obligations, we try to ensure that our messages all contain useful identity information and unsubscribe or preferences link in our messages—if you check the CEM itself, you will find clear instructions on how to stop receiving CEMs from us or manage your mail preferences. When you unsubscribe, it should happen very quickly – but as required by CASL we will make sure it occurs within 10 business days. If you have any questions or concerns about our unsubscribe methods, you may contact us at the address indicated below.
We keep your information only as long as we need it for legitimate business purposes and to meet any legal requirements. Personal information used to make a decision that directly affects an individual will be kept for at least one year after such a decision. We have retention standards that meet these parameters. We destroy your information when it is no longer needed or required to be kept, or we remove your personally identifiable information to render it anonymous.
If at any time you would like to unsubscribe from receiving future emails from us, you can do so by clicking the unsubscribe link in our email, or you can email us at info@simplicitycms.ca with the subject line “Unsubscribe” and we will promptly remove you from our mailing list.
We may update this Policy to reflect changes to our information practices. If we make any material changes we will either (a) notify you by email (sent to the e-mail address specified in your account), or (b) provide a notice on the Website or otherwise through the Service prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices. Any change to this Privacy Policy will become effective on the date so indicated, and will apply to information collected from the date of the posting of the revised privacy policy and to existing information held by us. The date on which the latest update was made is indicated at the bottom of this document. We recommend that you print a copy of this privacy policy for your reference and revisit this policy from time to time to ensure you are aware of any changes. Your continued use of the Service signifies your acceptance of any changes to this Policy.
You can direct any questions or concerns regarding our compliance with this Policy to our Privacy Officer by emailing at info@simplicitycms.ca.
If you are not satisfied with our Privacy Officer’s response to your question or concern you may be able to make a complaint under Applicable Privacy Laws. Our Privacy Officer can provide you with the contact information to make such a complaint.
End of Privacy Policy (Last Updated: June 29, 2022).
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