Application of this Policy
This Policy covers our collection, use and disclosure of information about identifiable individuals (“Personal Information”), particularly those individuals who use our Services (“User(s)”), as well as our customers (“Customer(s)”) and prospective Customers.
By using our Website, we assume you have consented to the use and disclosure of your Personal Information as outlined in this Policy. If you are submitting any Personal Information of a third party, you represent and warrant to ProNav that such individual has consented to ProNav’s collection, use and disclosure of their Personal Information.
Collection of Data
A) What We Collect
Our Customers’ and Users’ data is an intricate part of our business where we collect names, business contact information, billing information, titles, solely for the purpose of communicating with that person our Services’ information. We only collect, use and disclose Personal Information for the purpose of where consent has been granted in order to maintain, establish or manage our relationship with you and to provide products and services in which you have requested.
When a User visits our Website, we collect cookies and web beacons for the purpose of analytics and page tagging. If you visit our Website with a computer or mobile device, we will have access to your IP address, operating system version, browser type, etc. We do not share this information with any third-party companies.
If you provide your Personal Information through our “Get a Demo” or “Get in Touch” page, we will only use this information for the purpose of communicating with you to abide by your request. Individuals can opt out of receiving any e-mail marketing at any time.
B) How We Use It
Our Customers’ data is used to facilitate, enhance, support, and manage Customer accounts. It is also used by us to provide statistics and analytics to better measure our Customers’ performance and to assist in better management of their businesses. As a result of these performance indicators, we can improve our products and Services to provide more efficient tools for our Customers.
We will not use our Customers’ data for marketing materials, newsletter or any reasons where consent was not granted. We will seek new consent from our Customers for solicitation or marketing of any products or services from what our Customer originally partnered with us as part of adhering to Anti Spam Legislation.
Cookies are small text files sent by us to your computer and from your computer or mobile device to us each time you visit our Website or use our desktop application. They are unique to your account or your browser. Session-based cookies last only while your browser is open and are automatically deleted when you close your browser. Persistent cookies last until you or your browser delete them or until they expire.
Some cookies are associated with a User account. ProNav uses session cookies containing encrypted information to allow the system to uniquely identify a User account while the User is logged in. This information allows ProNav to process your online transactions and requests. Session cookies help us make sure you are who you say you are after you’ve logged in and are required in order to use the ProNav Services.
Other cookies are not tied to an Account but are unique and allow us to carry out site analytics and customization, among other similar things. ProNav uses persistent cookies, that only ProNav can read and use, to identify the fact that you are a ProNav user and track the webpages you view and use. If you access ProNav through your browser, you can manage your cookie settings there but if you disable some or all cookies you may not be able to use ProNav’s Services.
Finally, we use third parties like Google Analytics for website analytics, including those who visit the Website, such as the date and time, the search engine where the visitor comes from, the number of visits, etc. You may opt-out of third-party cookies from Google Analytics on its website.
Our third-party partners also employ clear gifs, images, and scripts that help them better manage content on our site.
You may be able to instruct your browser to refuse all cookies or to indicate when a cookie is being sent. Review your browser settings to set how to accept cookies, disable cookies or to notify you when receiving a new cookie. If you do not accept cookies, you may not be able to use some features of our Services and we recommend that you leave them turned on.
We use commercially reasonable efforts to store and maintain your Personal Information in a secure environment and take technical, contractual, administrative, and physical security steps designed to protect Personal Information that you provide to us. We believe in business principles, integrity and value for our business and our Customers’ businesses. We recommend not providing any personal data on any User content sites such as chat rooms, bots, message boards which ProNav provides access if you do not want others to access it. Please only send such data through private messaging, emails or via telephone if you feel you can trust the other party. We would like to remind our Users and Customers, that no data transmission is 100% safe; however, we will continue to enhance security procedures as new technologies develop and become available for the protection of our Customer base and employees.
3rd Party Sharing – Service Providers and Business Partners
A) Service Providers and Business Partners
We may from time to time employ other companies and people to perform tasks on our behalf and need to share Personal Information with them to provide the Services. Unless we tell you differently, such third parties do not have any right to use the Personal Information we share with them beyond what is necessary to assist us. This includes third-party companies and individuals employed by us to facilitate our ProNav Services. For a current list of our third-party sub-processors, please see below.
ProNav takes measures to prevent unauthorized access or use to Personal Information where we may store your Personal Information in systems within our control. We carefully review partnerships for their privacy measures and our partnerships agree to meet our standards for confidentiality and security. While we do carefully choose partnerships, these third parties are not operated or owned by us and we encourage Users to read the Privacy Policies of all external sites.
If you click on a link on our Website which takes you to a third party’s website, we cannot be responsible, assume responsibility for the privacy practices, policies or actions that operate on those websites.
B) Business Transfers
If we (or substantially all of our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information may be made available or otherwise transferred to the new controlling entity, where permitted under applicable law.
C) With Your Consent
D) For Legal Reasons
ProNav may disclose Personal information if we are under a duty to disclose or share your Personal Information in order to comply with any legal obligation, or in order to enforce or apply our Customer contracts and other agreements; or to protect our rights, property, or safety, our Customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction. All disclosures will be made in accordance with applicable laws.
Storage Location and Transfer of Personal Information
ProNav stores its data, including Personal Information, on servers located in Canada and the United States, including through the use of our third-party service providers, including our sub-processors listed here. By submitting information, you agree to this transfer, storing or processing of your Personal Information by our sub-processors in Canada and the United States. You acknowledge and agree that your Personal Information may be accessible to law enforcement and governmental agencies in Canada and the United States under lawful access regimes or court order.
Outside of Jurisdiction
Residents of California Privacy Rights
Subject to certain limitations, the California Consumer Privacy Act (CCPA) provides California consumers the right to request to know more details about the categories or specific pieces of Personal Information we collect (including how we use and disclose this Personal Information), to delete their Personal Information, to opt out of any “sales” of Personal Information that may be occurring, and to not be discriminated against for exercising these rights. ProNav does not sell (as that term is defined in the CCPA) the Personal Information we collect.
California consumers may make a request pursuant to their rights under the CCPA by contacting us at the contact information listed below.
We restrict anyone under the age of 18 from supplying, accessing or using our Services, supplying Personal Information and/or being employed by our company.
Access / Correction and Deletion
If you want to change, access, delete, update, verify or correct your Personal Information, please contact our Privacy Officer in writing at firstname.lastname@example.org. Please be aware, when requesting access, you may be required to provide specific information about yourself so we can verify and confirm your identity. Any refusal to verify and confirm your identity will result in us having to deny such requests. There may be certain instances where legislation allows us to refuse providing some or all information we have about you or as time limitations have caused the information to be destroyed or deleted in regards to our record retention.
Changes to Policy, Questions and Contact
From time to time, we will make changes to the policy in accordance with changes to our company or legislation. Use of Personal Information we collect is subject to the Policy in effect at the time such information is collected, used or disclosed. If we make material changes or changes in the way we use Personal Information, we will notify you by posting an announcement on our Website or Platform or by sending you an email prior to the change becoming effective. You are bound by any changes to the Policy when you use the Services after such changes have been first posted. In addition, we will ensure we visit our policy for any revisions annually or on as needed basis.
If you have any questions or concerns, please contact us in writing at email@example.com or via telephone. We will address your enquiry, and advise you of any steps required to address any issues raised. If our response is unsatisfactory, you have the right to contact the Privacy Commissioner of Ontario.
Our privacy officer is appointed to oversee the compliance. The contact information is as follows:
ProNav Technologies Ltd.
151 Charles Street West, Suite 100
Attention: Privacy Officer
To support ProNav in delivering its Services, ProNav engages third-party service providers as sub-processors.
This page identifies the sub-processor, describes where they are located, and what services they provide to us.
Our business needs may change from time to time and ProNav will periodically update this page to provide notice of additions and removals to our list of sub-processors.
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Last Updated: March 17, 2020