v1.0 May 2021
We will inform our users and customers of why and how we collect, use and disclose their personal information, obtain their consent where required, and only handle their personal information in a manner that a reasonable person would consider appropriate in the circumstances.
This Personal Information Protection Policy outlines the principles and practices we will follow in protecting users’ and customers’ personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our users’ and customers’ personal information and allowing our users and customers to request access to, and correction of, their personal information.
Scope of this Policy
This Personal Information Protection Policy applies to Commenty and any services provided by Commenty.
Personal Information – Information about an identifiable individual (E.g. including but not limited to name, age, home address and phone number, social insurance number, income, credit history, education, employment information). Personal information does not include contact information (described below).
Contact Information – Information that would enable an individual to be contacted at a place of business and includes name, position name or title, business telephone number, business address, business email or business fax number. Contact information is not covered by this policy.
Privacy Officers – The individuals designated responsibility for ensuring that Commenty complies with this policy.
Policy 1 – Collecting Personal Information
1.1 We collect information about you directly from you and automatically through your use of Commenty. We may combine information automatically collected with other information that we have collected about you including from publicly available sources. Commenty is not directed to children under thirteen (13) years or age and we do not knowingly collect personal information from children under 13. If we discover that a child under 13 has provided us with personal information, we will promptly delete such personal information from our systems.
1.2 The information we collect includes:
- Name, email, team name
- Billing information: If you purchase a Commenty subscription, our third-party payment processors will collect and store your billing address and credit card information. We store the last four digits of your credit card number, card type and the expiration date.
- Log and Device data: When you use Commenty, our servers automatically record information (“log data”), including information that your browser sends whenever you visit our website. This log data may include your web address you came from or are going to, your device model, operating system, browser type, unique device identifier, IP address, mobile network carrier, and time zone or location. Whether we collect some or all of this information often depends on what type of device you’re using and its settings. For example, different types of information are available depending on whether you’re using a Mac or a PC, or an iPhone or an Android phone. To learn more about what information your device makes available to us, please check the policies of your device manufacturer or software provider.
- Website Analytics: We use third party service providers such as Heap Analytics to provide certain analytics and user interactions services to Commenty, including the collection and tracking of certain data and information regarding the characteristics and activities of visitors to Commenty. You may opt-out of Heap Analytics’ cookies using Opt-Out Features on their respective websites.
1.3 We will only collect users and customers information that is necessary to fulfill the following purposes:
- To verify identity;
- To identify user and customer preferences;
- To open and manage an account;
- To deliver requested products and services;
- To ensure a high standard of service to our users and customers;
- To meet regulatory requirements;
- To communicate with you;
- To send you Commenty related promotional content (subject to opt-out preferences). We do not use your personal information to make automated decisions.
Policy 2 – Consent
2.1 We will obtain users’ and customers’ consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).
2.2 Consent can be provided orally, in writing, electronically or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the user or customer voluntarily provides personal information for that purpose.
2.3 Consent may also be implied where a user or customer is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs, the marketing of new services or products and the user or customer does not opt-out.
2.4 Subject to certain exceptions (e.g., the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), users and customers can withhold or withdraw their consent for Commenty to use their personal information in certain ways. A user’s or customer’s decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service or product. If so, we will explain the situation to assist the user or customer in making the decision.
2.5 We may collect, use or disclose personal information without the user or customer knowledge or consent in the following limited circumstances:
- When the collection, use or disclosure of personal information is permitted or required by law;
- In an emergency that threatens an individual’s life, health, or personal security;
- When the personal information is available from a public source (e.g., a telephone directory);
- When we require legal advice from a lawyer;
- For the purposes of collecting a debt;
- To protect ourselves from fraud;
- To investigate an anticipated breach of an agreement or a contravention of law
Policy 3 – Using and Disclosing Personal Information
3.1 We will only use or disclose user or customer personal information where necessary to fulfill the purposes identified at the time of collection or for a purpose reasonably related to those purposes such as:
- To conduct user or customer surveys in order to enhance the provision of our services;
- To contact our user or customer directly about products and services that may be of interest;
3.2 We will not use or disclose user or customer personal information for any additional purpose unless we obtain consent to do so.
3.3 We will not sell user or customer lists or personal information to other parties unless we have consent to do so.
Policy 4 – Retaining Personal Information
4.1 If we use user or customer personal information to make a decision that directly affects the user or customer, we will retain that personal information for at least one year so that the user or customer has a reasonable opportunity to request access to it.4.2Subject to policy 4.1, we will retain user or customer personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.
Policy 5 – Ensuring Accuracy of Personal Information
5.1 We will make reasonable efforts to ensure that user or customer personal information is accurate and complete where it may be used to make a decision about the user or customer or disclosed to another organization.
5.2 User or customer may request correction to their personal information in order to ensure its accuracy and completeness. A request to correct personal information must be made in writing and provide sufficient detail to identify the personal information and the correction being sought.
5.3 If the personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any organization to which we disclosed the personal information in the previous year. If the correction is not made, we will note the user’s or customer’s correction request in the file.
Policy 6 – Securing Personal Information
6.1 We are committed to ensuring the security of user and customer personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.
6.2 The following security measures will be followed to ensure that user and customer personal information is appropriately protected:
- The use of user IDs, passwords, encryption, firewalls;
- Restricting employee access to personal information as appropriate (i.e., only those that need to know will have access;
- Contractually requiring any service providers to provide comparable security measures.
6.3 We will use appropriate security measures when destroying user’s and customer’s personal information such as:
- Deleting electronically stored information
6.4 We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.
Policy 7 – Providing User or Customer Access to Personal Information
7.1 Users and customers have a right to access their personal information, subject to limited exceptions, including but not limited to:
- Disclosure would reveal personal information about another individual
- Health and safety concerns
7.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought.
7.3 Upon request, we will also tell users and customers how we use their personal information and to whom it has been disclosed if applicable.
7.4 We will make the requested information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request.
7.5 If a request is refused in full or in part, we will notify the user or customer in writing, providing the reasons for refusal and the recourse available to the user or customer.
Policy 8 – Questions and Complaints: The Role of the Privacy Officers
8.1 The Privacy Officers or designated individuals are responsible for ensuring Commenty’s compliance with this policy.
8.2 Users and customer should direct any complaints, concerns or questions regarding Commenty’s compliance in writing to the Privacy Officers. If the Privacy Officers are unable to resolve the concern, the user or customer may also write to the Information and Privacy Commissioner of Ontario.
Contact information for Commenty’s Privacy Officers:
- Loc Nguyen
- Barrett Le
Contact email: firstname.lastname@example.org