Last updated May 23rd, 2018

This website is owned and operated by eSentire Inc. (“eSentire”). We are committed to protecting the privacy of our visitors while they interact with the content, products and services on this site (the “Site”). This privacy policy (the “Privacy Policy”) applies to the Site and any other content, products, applications, features, functionality, information and services offered by us through the Site. It does not apply to other third party websites to which we link. Because we gather certain types of information about our users, we want you to understand what information we collect about you, how we collect it, how that information is used, and any choices you may have to control our disclosure of it.

  1. ACCEPTANCE OF THIS PRIVACY POLICY

    In order to run our business and to provide you with our products and services, we require certain personal information (“your personal information”) that includes information that identifies you and, with regard to the need to meet certain legal requirements, the location from which you send us your personal information. We will take commercially reasonable measures to protect your privacy and security your information, but if you do not agree with this Privacy Policy or the additional descriptions of how we process your personal information (how we use, share, disclose, store and delete it), you should not use our services, or any other function offered by the Site. By clicking the “Accept” button in our Terms and Conditions, you agree to this Policy and provide consent as indicated in the “Sharing or Personal Information With Third Parties” section of this Policy.

  2. INFORMATION WE COLLECT

    We collect two types of information from you: (i) information that you voluntarily provide to us (e.g. through a voluntary registration process, sign-ups or emails); and (ii) information that is derived through automated tracking mechanisms, such as cookies and data analysis tools.

    1. Voluntary Registration Information

      We also collect personally identifiable information, which may include but is not limited to, your email address, legal name, date of birth, the IP address of the device with which you communicate with us and certain account information. We also collect personally identifiable information when you choose to use certain features of the Site, including without limitation: (i) information you provide so that we may send you emails about upcoming promotions or events; (ii) Information you provide to us in order for you to receive downloaded resources such as data sheets and white papers; (iii) participating in our forum/blog; or (iv) commenting on articles or other content on the Site. When you choose to use these additional features, we require that you provide us with your “Contact Information” in addition to other personal information that may be required to complete a request form.

    2. Automatic Data Collection: Cookies and Related Technologies

      With your consent, we use “cookies” and other tracking technologies. Cookies are small files we use to store user preferences and enhance users’ experience with the Site. Cookies also enable us to serve secure pages to our users without asking them to sign in repeatedly. Most internet browsers allow you to control cookies, including whether or not to accept them and how to remove them. Cookies will expire if a user’s system is idle for a defined period of time. Once a cookie expires, the user must sign in again to continue their session. This prevents unauthorised access to the user’s information while they are away from their computer.

      You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your internet browser’s settings. If you choose to erase or block cookies, you may limit our ability to offer you certain services or features, and will need to re-enter your login credentials to gain access to certain parts of the Site.

      We use cookies and other forms of analytics technology to better understand our users’ needs and to optimize the Site. These technologies help us understand our users’ experience (e.g. how much time spent on which pages of the Site, which links are clicked, what users do and do not like, etc.) to enable us to build and maintain the Site with user feedback. We use cookies and other technologies to collect data on you, including without limitation how you interact with the Site, what you click and the keys you press, the pages you visit, your location (country only), the date and time you access the Site, the language you prefer the Site is displayed in, and the URL and domain that referred you to the Site. These technologies may also collect your device’s IP address (in an anonymized format), screen resolution, unique device identifiers, operating system and browser type, location, and preferred language to display the Site. We may store this information in an anonymized user profile. We will not use this information to identify individual users or match it with data on an individual user.

  3. HOW WE USE INFORMATION

    If you elect to provide us personal information, we may use it as needed to deliver products and/or service to you. We may use personal information in a variety of ways to meet our obligations to you to provide you with a variety of products and services. These uses are based in our legitimate business interests in providing products and services to you; fulfillment of our contractual obligation to deliver products and services you have requested; meeting our legal obligations; establishment or defense of a legal claim; or your consent (which you can withdraw or revoke at any time); or a necessity to protect your vital interests or the interests of others. We have balanced our business interests carefully with your privacy rights and these uses do not improperly infringe on your privacy and confidentiality rights. These business uses for your personal information include the following:

    • If you create an account - your username, password, your city of birth, your birthday and mobile phone number.
    • If you use our mobile applications - information such as your device ID, your location and stores near you and visited by you may be collected
    • If you take a survey or interact with us in various other ways - demographics information and information about subjects that may interest you.
    • Fulfilment of your orders for products or services.
    • Your inquiries sent to our offices or our website.
    • Analytics and cookies (described in greater detail below), if you consent.
    • If you sign up for an event for which registration is open to the public, your name, company name and other identify information may be viewed by others (though in certain jurisdictions we would only make it available in this way with your consent).
    • We may also collect aggregated data or anonymized data that does not directly identify you.

    eSentire only uses your personal information for the original purposes it was given. The information you provide to us is used provide you with a more enjoyable, convenient online experience and to help us identify and/or provide information, products or services that may be of interest to you. We use your personally identifiable information to support and enhance your use of the Site and its features, including without limitation: fulfilling your order; providing customer service; tracking email invitations you send; and otherwise supporting your use of the Site. eSentire may use your personal information for targeted advertising toward you based on things such as region, interests, habits, etc.

    We may permit certain trusted third parties to track Site usage, analyse data such as the source address that a page request is coming from, your IP address or domain name, the date and time of the page request, the referring Web site (if any) and other parameters in the URL. We have entered into written agreements with these third parties in which they agree to maintain safeguards for the privacy and security of your personal information. This information is collected in order to better understand our website usage, and enhance the performance of services to maintain and operate the Site and certain features on the Site. We may use third parties to host the Site; operate various features available on the Site; send emails; analyse data; provide search results and links etc.

    From time to time we may use your personal information for new, unanticipated uses not previously disclosed in our Privacy Policy. If our information practices change at some time in the future, we will post the policy changes to our website.

  4. HOW WE SHARE INFORMATION WITH THIRD PARTIES

    We do not sell, rent, lease or disclose your personally identifiable information to third parties, except as described in the Privacy Policy. Our affiliated companies, including all of their respective business units, subsidiaries, parents, affiliates and sites may obtain from us and use your personally identifiable information in accordance with the Privacy Policy. We may transfer personally identifiable information as an asset in connection with a proposed or actual merger or sale (including any transfers made as part of an insolvency or bankruptcy proceeding) involving all or part of our business or as part of a corporate reorganisation, stock sale or other change in control.

    We also have may to disclose your personally identifiable information and other information to third parties, which we call “Third Party Service Providers”, who provide services for us in pursuit of our legitimate business interests for, among other things, the purposes of administering, maintaining and improving the Site. We will generally use contractual or other means to provide a comparable level of protection while personally identifiable information is being temporarily stored and/or processed by Third Party Service Providers. Third Party Service Providers may only use your personally identifiable information to provide us with a specific service and not for any other purpose. We have assessed these business interests and determined that they do not impinge on your rights as set forth in this Privacy Policy and as protected by law.

    We may also access or disclose personally identifiable information in the following circumstances: (i) to identify, contact or bring legal action against someone who may be violating our terms and conditions of use or may be causing injury or interference with our rights, property, our customers or anyone who could be harmed by such activities; (ii) to protect the safety and security of the Site and our users; (iii) if we believe your actions violate our Terms and Conditions or this Privacy Policy; or (v) to comply with law, regulation, court order, subpoena, government request, or legal process.

    Your consent will be sought if your personally identifiable information will be provided to any third party for any reason other than as set forth in this Privacy Policy.

    We use non-identifying and aggregate information to better design our website and for business and administrative purposes. We may also use or share with third parties for any purpose aggregated data that contains no personally identifiable information.

    TO THE EXTENT PERMISSIBLE BY APPLICABLE LAW, WE ARE NOT LIABLE OR RESPONSIBLE FOR THE COLLECTION, USE OR DISCLOSURE BY THIRD PARTIES OF PERSONALLY IDENTIFIABLE OR OTHER INFORMATION YOU CHOOSE TO SUBMIT IN FORUMS PUBLICLY ACCESSIBLE AREA OF THE SITE.

  5. SECURITY: HOW WE PROTECT YOUR INFORMATION

    While no data transmission over the internet is 100% secure, we are committed to protecting the information we receive from you. We take appropriate security measures to protect your information against unauthorised access to or unauthorised alteration, disclosure or destruction of data. To prevent unauthorised access, maintain data accuracy, and ensure the correct use of information, we maintain appropriate physical, electronic, and managerial procedures to safeguard and secure the information and data stored on our system. While no computer system is completely secure, we believe the measures we have implemented reduce the likelihood of security problems to a level appropriate to the type of data involved.

    The Site may contain links to other websites that we do not own or control. The Privacy Policy does not apply to these websites and we are not responsible for the privacy practices of such websites or other services operated by such websites. Once you leave the Site via such a link, we recommend your review the privacy policy applicable to such third party websites to learn how they use and disclosure your personally identifiable information.

  6. RIGHT TO OBJECT

    You may object to eSentire using your personal information for the above purposes at any time by contacting [email protected] If you do so, eSentire will cease using your personal information for the above purposes (i.e., under a legitimate interest set out above) and remove it from its systems unless such personal information is permitted to be used by eSentire for another purpose set out in this Privacy Policy or eSentire determines and demonstrates a compelling legitimate interest to continue in processing your personal information.

  7. CHOICE AND CONTROL; ACCESSING AND UPDATING YOUR PERSONAL INFORMATION AND PREFERENCEs

    We provide mechanisms for updating and correcting your personal information for many of our services. You may modify or remove any of your personal information at any time by emailing [email protected] It is your responsibility to give us current, complete, truthful and accurate information, including personally identifiable information and to keep such information up to date. We cannot and will not be responsible for any problems or liability that may arise if you do not give us accurate, truthful or complete information of if you fail to update such information.

    You may withdraw your consent or otherwise object to uses of your information as described above by contacting [email protected] You may also withdraw your consent to email marketing by unsubscribing, using the unsubscribe link in such communications. If you do so, eSentire will cease using your personal information for the above purposes and remove it from its systems unless such personal information is permitted to be used by eSentire for another purpose set out in this Privacy Policy or eSentire determines and demonstrates a compelling legitimate interest to continue in processing your personal information In case of withdrawal of consent, eSentire will not process your personal information subject to this consent any longer unless legally required to do so. In case eSentire is required to retain your personal information for legal reasons, your personal information will be restricted from further processing and only retained for the term required by law. However, any withdrawal has no effect on past processing of personal information by eSentire up to the point in time of your withdrawal. Furthermore, if your use of an eSentire offering requires your prior consent, eSentire will not be (any longer) able to provide the relevant product, service, offer, or event to you after your withdrawal Please direct any such request for withdrawal to, or write to eSentire at [email protected]

    Depending upon your location, you may benefit from a number of rights with regard to your personal information that we process. These rights are defined and, in some cases limited, by the laws of your jurisdiction. These rights include (a) data portability, including the right to obtain a copy of the personal information you have provided to eSentire and transfer it elsewhere; (b) data correction (also known as rectification, including the ability to request correction or amendment of your personal information and (c) data deletion, including the right to have eSentire delete your personal information except for information that we are required to retain. However, any request to have your information deleted, or any request to have eSentire cease processing of your personal information, will have no effect on past processing of personal information by eSentire up to the point in time of your request. Furthermore, eSentire will not be (any longer) able to provide the relevant product, service, offer, or event to you after the deletion of your personal information unless you resubmit your information to eSentire.

    Your right to have eSentire delete your personal information is dependent upon the following events: (i) you state that the personal information eSentire has about you is incorrect; but ESentire may retain the information for as long as it requires to check the accuracy of the relevant personal information; (ii) there is no legal basis for eSentire’s processing of your personal information and you demand that eSentire restrict your personal information from further processing, (iii) eSentire no longer requires your personal information but you claim that you require such data in order to claim or exercise legal rights or to defend against third party claims; or (iv) in case you object to the processing of your personal information by eSentire it may retain and process the information for as long as it is required to review as to whether eSentire has a prevailing interest or legal obligation in continuing to process your personal information. Your right to have your personal information deleted does not apply where the information is necessary:

    1. for exercising the right of freedom of expression and information;
    2. for compliance with a legal obligation which requires processing by European Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
    3. for reasons of public interest in the area of public health in accordance with points (h) and (i) of Article 9(2) as well as Article 9(3);
    4. for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
    5. for the establishment, exercise or defense of legal claims.

    You may inquire about the exercise of these rights and, if the laws of your jurisdiction permit, exercise them as permitted by law by [email protected]

  8. DURATION AND RETENTION

    eSentire will retain your personal information only for as long as is necessary for the purposes set out in this Policy, or as required or permitted by law, and then will delete it as required by law. For example, eSentire will retain your information as long as required to comply with applicable tax/revenue laws, cybersecurity and privacy laws, laws and regulations that affect the conduct of our business; to resolve disputes, enforce our agreements, cooperate with law enforcement requests or to meet other legal obligations. We may also retain log files for internal analysis purposes, though we would retain them for only a brief period except in cases where we are legally required to retain them for longer periods, and in cases where they are used for site safety and security or to improve website functionality.

  9. INTERNATIONAL TRANSFERS

    eSentire operates in Canada, the United States and Europe. By using our products and services you understand and agree that your personal information may be transferred from the European Economic Area (EEA, which comprises the European Union countries plus Norway, Iceland, Liechtenstein) to a country that does not have an equivalent level of data protection, such as the United States. When your personal information is transferred from your home country to another country, the laws and regulations that protect your personal information may be different than those in your home country. In particular, if your information is in the US, it may be accessed by government authorities in accordance with US law.

    To the extent that eSentire is deemed to transfer your personal information outside the EEA to a country that has not received a data protection equivalency determination form the European Commission (Canada has received such a determination), eSentire will rely upon data transfer agreements with Model Contract Clauses, which the European Commission has adopted to provide safeguards for personal information that is transferred outside the EEA. You may obtain a copy of the Model Clauses by contacting [email protected]

  10. YOUR RIGHTS WITH RESPECT TO YOUR PERSONAL INFORMATION

    You can request from eSentire at any time information about which personal information eSentire processes about you and the correction or deletion of such personal information. If eSentire uses your personal information to perform a contract with you, you may further request a copy of the personal data that you have provided to us. To make such a request, please contact the email set forth in Section 11 below and specify in detail the information or the activity to which your request relates, the format in which you would like the personal data returned and the recipient, you or your designee. Furthermore, you may contact eSentire if you believe that the personal information that eSentire has is incorrect.

  11. CONTACT AND EU REPRESENTATIVE

    If you have questions regarding this Privacy Policy, wish to lodge a complaint or wish to exercise the rights in the Choice and Control section of the Policy, you may contact [email protected]

  12. GOVERNING LAW

    To the extent permitted by the laws of your jurisdiction, this Privacy Policy shall be governed by and construed in accordance with the laws of the Province of Ontario and the federal laws of Canada applicable therein. You hereby irrevocably submit and attorn to the jurisdiction of the courts of the Province of Ontario, and the proper courts of appeal there from, over any action or proceeding arising out of or relating to the Privacy Policy and you irrevocably agree that all claims in respect of such action or proceeding may be heard and determined in such courts.

  13. UPDATES TO THIS PRIVACY POLICY

    eSentire may revise the Privacy Policy from time to time. If in the future there is a change to our Privacy Policy, we will post the new Privacy Policy to the Site. We recommend you periodically review the Site to ensure you are familiar with the current version of this Privacy Policy. The date of the last update to this Privacy Policy appears at the top of this Privacy Policy. Please see our Terms and Conditions for other terms and conditions governing your use of the Site.