PRIVACY POLICY
Last Updated: July 28th, 2023
At Sapper Laps Group Inc. your privacy is important to us. We are committed to providing you with exceptional service while protecting your privacy and safeguarding your personal information. Personal information means information that can identify an individual, for example, a person’s name, home address, phone number or ID number (the “Personal Information”).
This policy applies to our software (the “Software”), either in an on-premises or cloud/hosted deployment. This privacy policy is incorporated into our End User License Agreement. Capitalized terms not defined in this privacy policy will have the definition given to them in the End User License Agreement.
Why we collect and use Personal Information
Collecting personal information about you is essential to being able to provide the products, services and Software that best meet the needs of you and/or your clients (“Clients”). While the personal information we collect may come directly from you, it may also be provided by third parties. The purpose for which Personal Information is collected will be identified before or at the time it is collected or will otherwise be set out in this privacy policy.
We collect and may retain the following:
information you enter into the system for your account and documents. Your account information includes your name, address, and billing information. Documents may contain the content you enter into each document, collaborators, print history, version history and billing history;
information related to documents to permit you to organize and categorize them, including clients, matters, tags and categories;
billing information related to your use of the Software;
User Submissions;
technical logs used to operate and maintain the Software. In particular, we log the production of access to web pages and errors in our Software; and
anonymous usage statistics through Google Analytics to keep track of use of the Software.
We use your information (including Personal Information) to: determine eligibility for products, services and the Software; process orders for Clients, and provide requested information, products, services or Software; and billing and accounting services relating to our products and Software. Personal Information may also be used for other purposes, subject to obtaining your prior consent for such use.
For marketing purposes, we may use anonymous statistical information, for example the number of users on the system and number of transactions undertaken in aggregate or on average. Note that third party service providers (such as the internet browser, Chrome) may also collect anonymous statistical information when the Software is used. We have no control over the information collected by third party service providers and such information is not covered by this Privacy Policy.
Consent to use Personal Information
Your consent will be obtained for the collection, use or disclosure of Personal Information, except where the law provides an exemption, and any Personal Information we collect will be limited only to that which is necessary for the purposes identified. Consent may be obtained in various ways. We may obtain your express consent, or we may determine that consent has been implied by the circumstances. Express consent could be in writing (for example in a signed consent, e-mail or application form), or orally in person or over the telephone. When we receive Personal Information from you that enables us to provide you with a requested product, service or Software, your consent to allow us to deal with that Personal Information in a reasonable manner would be implied. If you need to provide Personal Information about other individuals (such as your Clients, employees, dependents, a spouse, etc.), you must obtain their consent for these purposes prior to your disclosure to us.
Providing us with your Personal Information is always your choice. When you request the Software from us, we ask that you provide information that enables us to respond to your request. In doing so, you consent to our collection, use and disclosure to appropriate third parties of such Personal Information for these purposes. You also authorize us to use and retain this Personal Information for as long as it may be required for the purposes described above. Your consent remains valid even after the termination of our relationship with you, unless you provide us with written notice that such consent is withdrawn. By withdrawing your consent, or by not providing it initially, you may limit or even prevent us from being able to provide you or an authorized third party with the products or Software desired.
Length of storage
Personal Information will only be used or disclosed for the purposes for which it was collected, unless you have otherwise consented or when it is required or permitted by law. Personal Information will be retained only as long as necessary for the fulfillment of those purposes.
Security
The security of your Personal Information is important to us but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.
Cookies and local storage
We or our third-party service providers may send “cookies” to or use “localStorage” on your computer. “Cookies” contain no information about you but rather are unique numbers used to track user activity at a website. This data is stored on your computer to facilitate the third-party services, and in addition for us to:
identify you between connections to our Software;
return you to the last known location you were editing; and
maintain a copy of certain information on your local computer in the event of a disconnection from our Software.
If you do not wish to have cookies placed on your computer, you should set your browser to refuse cookies before using the Software, with the drawback that certain features of the Software may not function properly without the aid of cookies.
By continuing to navigate our website without changing your cookie settings, you hereby acknowledge and agree to the use of cookies.
Third party links
Our website may contain links to other third-party sites that are not governed by this privacy policy. Although we endeavor to link only to sites with high privacy standards, our privacy policy will no longer apply once you leave one of our websites. We are not responsible for privacy policies employed by third parties. We suggest, therefore, that you examine the privacy statements of those sites to learn how personal information may be collected, used and/or disclosed by them.
Notifications and notices
We may send you notices and contact you to collect on unpaid fees owed to us. We may employ third-party collection agencies to collect unpaid fees, and disclose to them any of your information is necessary for them to collect the fees from you.
Authorized sharing
We do share your data with third-parties that provide the underlying services that are essential to our Software. We do not assume or incorporate any privacy policies or terms and conditions of those third-parties or their websites into this privacy policy. Agreement to our End User License Agreement is an acknowledgment of and consent to our use of those essential third-party services and agreement by you that your data may be subject to privacy policies of those third-party service providers.
Control over your information
You can update your account information and preferences at any time. You can delete information associated with your account when you choose. We will retain, and you give us your consent to retain, data related to any unpaid debts owing to us for the purpose of collection.
It is important that your Personal Information is accurate and complete. Having accurate information about you enables us to give you the best possible products, services and Software. You have the right to access, verify and amend the information we have about you. We rely on you to keep us informed of any changes, such as a change of address, telephone number or any other circumstances.
Despite our best efforts, errors occasionally can occur. If you identify any personal information that is out-of-date, incorrect or incomplete, please inform us right away and we will endeavor to make the corrections promptly and to use all reasonable efforts to communicate these changes to other parties who may have inadvertently received incorrect or out-of-date personal information from us.
Access to information
We only access your information when:
you specifically ask us to (e.g. for technical support);
it is required by law; and
it is necessary to maintain our system.
Selling, renting or sharing information
We will not sell, rent or share your personal information, except if and as you direct us to do so.
Legal requests for disclosure
To protect your privacy, we will not disclose your personal information to law enforcement, other government officials, or other third parties without a subpoena, court order or substantially similar legal procedure (a “Legal Request”), except when we reasonably believe in good faith that the disclosure of information is necessary to prevent imminent physical harm or financial loss.
Where we receive a Legal Request to disclose Personal Information, we will make all commercially reasonable efforts to notify you of the request. If you do not respond to us, we will take all commercially reasonable steps to delay disclosure of your Personal Information until you have responded to our notice. Whether you acknowledge receipt of our notice, or we are ultimately compelled through a Legal Request to disclose your Personal Information notwithstanding that you have failed to respond to our notice, we assume no responsibility for, nor liability arising out of, that Legal Request for disclosure of your personal information.
It is your responsibility to respond to the Legal Request, and we will take no further steps (except provide disclosure as required by the Legal Request).
If you fail to acknowledge receipt of our notice of a Legal Request, in order to protect your Personal Information, we may need to retain legal counsel to attend at Court, and you authorize us to do, to advise the Court that we shall not disclose your Personal Information without your prior consent unless the Court issues an Order compelling us to make disclosure. In the foregoing instance, we will disclose to the Court all information regarding our attempts to contact you about the Legal Request.
You agree to assume, and do hereby assume, full responsibility for repayment to us of all reasonable costs we incur in trying to protect your Personal Information, including for attempts at service, legal fees and adverse costs awards arising from our refusal to consent to the disclosure of your Personal Information. If we incur any of the foregoing costs, we will advise you of them by way of an invoice setting out the costs together with a reasonably detailed description of the basis on which those costs were incurred. Such costs will be added to any account balance you may have and will be paid by you within 30 days of posting to your account.
Succession
In the event of a merger, acquisition, reorganization, bankruptcy, or other similar event, certain information in our possession may be transferred to our successor or assignee. How we protect your information, although no data transmission can be guaranteed to be 100% secure, we employ physical, electronic and procedural safeguards to protect our systems and all Personal Information stored in our servers, which are located within and outside of Canada, against unauthorized access and use. You hereby consent to our transfer of your Personal Information between our Canadian and non-Canadian servers, if and as necessary to provide the Software. All safety and security measures are appropriate to the sensitivity level of the information collected. Our team members are governed by strict standards and policies to ensure that Personal Information is secure and treated with the utmost care and respect.
Access to information is limited (through user/password credentials and software systems) to those employees who require it to perform their job functions in providing you with the products and Software. We use industry-standard Secure Socket Layer (SSL) encryption technology to safeguard the account registration process and sign-up information. Other security safeguards include but are not limited to data encryption, firewalls, and physical access controls to building and files.
Representations
You represent to us that you are in compliance with all applicable privacy laws, you have obtained all necessary rights and consents under applicable law to disclose to us, or allow us to collect, use, retain and disclose any information that you provide to us or authorize us to collect and that we will not be in breach of any such laws by collecting, receiving, using and disclosing such information in connection with the Software. As between you and us, you are solely responsible for disclosing to your Clients that we will hold and communicate Information for you on their behalf and will obtain data from you about those Clients. We may provide some or all of the Software from systems located within the United States or other countries outside of Canada. As such, it is your obligation to disclose to your Clients that Information may be transferred, processed and stored outside of Canada and, as set forth in this privacy policy, may be subject to disclosure as required by applicable law. If you receive information about others, including your Clients, through the use of the Software, you must keep that information confidential and only use it in connection with the Software. You may not disclose or distribute any such information to a third party or use any such information for marketing purposes unless you receive the express consent of its owner to do so.
Change of policy
We reserve the right, in our sole and absolute discretion, to make changes to this policy from time to time. It is your responsibility to check this privacy policy from time to time to make yourself aware of any changes we may make to it.
Contact
Attn: Information and Privacy Officer
Sapper Labs Group Inc.
Ottawa, Ontario, Canada
info@sapperlabs.com