1.1 Our Commitment to Privacy
You are a “User” if you are an individual and you access our website located at https://www.getprovision.co or http://www.useprovision.com and related webpages (collectively, the “Site”), install or use any other software supplied by us, access any information, function, feature, application, product or service made available by us or register an account with us (collectively, the “Service”).
Your “personal information” means any information about you as defined in applicable Privacy Laws and includes information such as your full name, address, postal code, email address and geographic location. It may also include information on how you use the Service. It does not include business contact information or certain publicly available information.
We may collect personal information when you provide it to us, including by way of your interaction with us and your access and use of our Service. We try to minimize the collection of personal information to only what is reasonable and necessary to provide our Service and to develop, assess and improve our Service. We only collect personal information if non-identifying information is not sufficient for this purpose.
We may collect the following categories of personal information about you:
• identifiers, which may include your name, address, email address, telephone number, user ID, username or screen name, password, IP address or MAC address; • commercial information, which may include payment, banking or other financial information;
• internet or network activity, which may include your operating system type and version, web server type and version, PHP version, database type and version, cookie information, device information, browsing information, browsing activities, platform use data, mobile use data, referring domain, destination domain, destination path, performance, security, software configuration, website user statistics, viewing activity and communication preferences;
• mobile device information, which may include your mobile phone number, mobile country code, unique device identifier, mobile advertising identifier (assigned by your mobile platform), information about your mobile device screen size, date and time of mobile device use and other mobile device-related information;
• geolocation information, which may include geographical information derived from your IP address, MAC address or device GPS;
• audio, visual or electronic information, which may include screen sharing views or any data contained in files uploaded, emailed or otherwise provided by you; • information from third parties (where you have authorized it); and
• other information, which may include the contents of your communications with us, whether through email, social media, telephone or otherwise, and inferences we may make from other personal information we collect.
3. USE AND DISCLOSURE
3.1 Purposes of Use and Disclosure
We may use or disclose the personal information we collect about you for the following purposes:
• to verify your identity;
• to contact you or your designated representatives;
• to manage the administration of your account;
• to provide you with our Service;
• to maintain and improve our Service;
• to develop new services;
• to advertise, market and promote our Service;
• to identify new users or customers;
• to measure our performance;
• to tailor the content and advertising on our Site and other services;
• to manage your preferences;
• to provide a more personalized user experience;
• to monitor your compliance with any of your agreements with us;
• to satisfy our legal, regulatory and tax reporting requirements;
• to establish our legal rights or defend against legal claims;
• to protect you, us and others from fraud and error and to safeguard our business interests;
• to collect debts owed to us;
• to manage or transfer our assets or liabilities, which may include in the event of an acquisition, disposition, merger, amalgamation or other business transition or transaction; and
• for any other purpose which we disclose to you from time to time.
If we ever wish to use or disclose the personal information we collect about you for a purpose not previously identified, the new purpose will disclosed to you prior to such use or disclosure and your consent to such use or disclosure will be sought (unless such use or disclosure is required or authorized by law).
3.2 Third Party Use and Disclosure
To the extent permitted by applicable law, we may disclose the personal information we collect about you to the following third parties:
• our affiliates, agents or business partners;
• our service providers, which may include service providers of website hosting, payment processing, product delivery, accounting, legal, tax, consulting, professional advising, surveys, market research, data analysis, reporting, and marketing services;
• a purchaser, investor, new affiliate or other successor in the event that we or any affiliate, portion, group or business unit of ours undergoes an acquisition, disposition, merger, amalgamation or other business transition or transaction;
• legal, governmental, regulatory, tax or judicial authorities (“Authorities”) to comply with any law, directive, judicial or administrative order, legal process, investigation, warrant, subpoena, government request, regulatory request or as otherwise required or authorized by law or such Authorities; and
Whenever we disclose personal information to third parties, we try to minimize the disclosure of personal information to only what is reasonable and necessary for the third party to fulfill the particular purpose for disclosure. We also require, by contractual means, that the third party maintain and protect the confidentiality of the disclosed personal information to the same degree as it if were in our possession.
At times, we may transfer your personal information outside of Canada, including to third parties outside of Canada who may perform services for us which involve some of the personal information we collect about you. Accordingly, some of your information may be processed or stored in the jurisdiction where the third party is located. This information is subject to both the laws of Canada and the laws of the third party's jurisdiction and may be accessible by the Authorities of other jurisdictions. When we transfer personal information to third parties, we ensure by contractual means that the transferred personal information is protected to the same degree as if it were in our possession.
4.1 Obtaining Consent
We will not collect, use or disclose your personal information without first obtaining your consent (except where required or authorized by law). Your consent can be express, implied or given through an authorized representative, such as a lawyer, agent or broker.
4.2 Withdrawing Consent
You may also withdraw all or part of your consent to receive promotional emails from us by following the opt out instructions provided in such emails. If you opt-out, we may still send you non-promotional emails, such as messages about your account or our ongoing business relations.
We try to ensure that the personal information we collect about you is accurate, complete and up to date. In some cases, we rely on you to ensure that certain personal information, such as your address or telephone number, is accurate, complete and up to date. Users are requested to notify us as soon as possible of any changes, deletions or corrections to their personal information so that we may keep such information up to date.
With certain limited exceptions as provided under applicable Privacy Laws, you have the right to access your personal information held by us and to request that the information be corrected if it is inaccurate, incomplete or collected in violation of law. You may update or correct information about yourself by contacting us in accordance with Section 7. Please note that we may be unable to provide you with full access to your personal information if we are prohibited by law or regulatory reasons to do so, or if the information has been securely destroyed in accordance with our practices. Subject to legal or contractual restrictions, we will provide you with an explanation if we are unable to fulfill your access request. In accordance with applicable law, we must take steps to verify your identity before fulfilling any of the above requests. If you maintain an account with us, we may verify your identity through existing authentication practices for the account, such as your username and password. We may also verify your identity by matching two or three data points of identifying information about you.
We maintain physical, electronic and procedural controls consistent with regulatory standards to protect the personal information in our custody or control. Reasonable measures, such as system access security controls, safeguards to detect and prevent security system failures, restricted access, and employee training, have been implemented to help protect personal information from unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks. We also take reasonable steps, through contractual or other reasonable means, to ensure that a comparable level of personal information protection is implemented by the third parties who assist us in providing products and services to you. However, please note that complete and permanent confidentiality and security cannot be guaranteed when information is transmitted electronically.
You can also play an important role in protecting your personal information. For example, you should:
• create a strong and unique password for your user accounts;
• never share your user accounts or passwords with anyone (note that we will never ask you for your password, including in any unsolicited communication such as letters, telephone calls or emails);
• log out of your user account each time you are finished using it, especially if you share your device with others;
• use a strong and unique password on your device; and
• never post information on our Site that you do not want to be viewed or used by others. 5.4 Retention and Disposal
6. OTHER DATA PRACTICES
6.1 Cookies and Similar Technologies
6.2 Aggregated and Anonymized Personal Information
Our Service is not targeted or directed at children under the age of 13, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 13. If you have reason to believe that a child under the age of 13 has provided personal information to us, we encourage the child’s parent or guardian to contact us in accordance with Section 7 to request that we remove the information from our systems. If we learn that any personal information we collected has been provided by a child under the age of 13, we will promptly delete that personal information.
6.4 External Websites
6.5 Disclaimer to Complete Security
7. CONTACT US
7.1 Contact Us
If you have questions or complaints with respect to our privacy policies and practices or if you wish to request access to, or correction of, your personal information under our care and control, please contact our Privacy Officer at:
Attention: Provision Software Corporation
Mailing Address: 155 Wellington Street West, 40th Floor
M5V 3J7 Canada
Inquiries or complaints will be dealt with promptly. We will acknowledge your query, investigate it and provide you with a response within 30 days.
7.2 File a Complaint
Address: Office of the Privacy
Commissioner of Canada
30 Victoria Street
Gatineau, QC K1A 1H3
Last Updated: September 28, 2022