This Privacy Policy was last updated on, and is effective as of, April 5, 2019.
Welcome to our website www.RightLabs.com (the “Website”), which is operated by TransACT Communications Canada Ltd., d/b/a RightLabs (“RightLabs”, the “Company”, “we” or “us”). This Privacy Policy (“Privacy Policy”) is intended to inform you of the ways in which we collect and handle information for the Website, the uses that we make of that information, and the ways in which we will protect any personal information you choose to provide us.
By using the Website, you consent to the collection, use and transfer of your information in accordance with this Privacy Policy. If you do not agree to this Privacy Policy, please do not use this Website.
Summary
RightLabs is committed to protecting the privacy of users who visit our Website. We collect information as part of our Website operations and service offerings and related processes. We fiercely protect your personal information and RightLabs doesn’t sell your personal information to anyone. The above is just a summary. However, RightLabs’ lawyers requested that we also provide you the additional details below.
Overview
RightLabs is a Canadian company headquartered in the Province of Alberta that services the needs of North American organizations, which are primarily not-for-profit organizations that host, promote, conduct and administer events. One of our tenets of operational excellence is the methods and standards we provide around the protection of personal information both collected on behalf of and disclosed to our customers and other third parties in all of our business operations. This Privacy Policy is a formal statement of principles and practices concerning the protection and handling of personal information collected through the Website and the service offered through the Website. RightLabs will regularly review its Privacy Policy to ensure that it is relevant and remains current with changing technologies and laws. Most importantly, RightLabs wants to ensure it continues to meet the evolving needs of our Website users whose Personal Information is collected through the Website.
We may collect information that our Website users provide or visitors volunteer to us, including but not be limited, information about them as an identifiable person, such as name, date of birth, postal address, email address, telephone numbers, cell phone numbers, gender, credit information, personal preferences and other personal information (collectively, “Personal Information”), but does not include aggregated information that cannot be associated with a specific individual. Any Personal Information you send us will be used for the purposes indicated on the Website or as stated in this Privacy Policy.
Personal Information will be held by us and may be used by us and our affiliated companies and their agents, partners or licensees. We will not sell, exchange or otherwise distribute your Personal Information to unaffiliated third parties without your consent, except to the extent required by law, or as set out in this Privacy Policy, including as follows:
The Personal Information we receive will be used in our marketing, promotion and advertising of the Website. As a result of providing us with your contact information, we may contact you by sending you mailings or other communications (electronic or otherwise) regarding the Website and products, services, promotions, or upcoming events that we believe may be of interest to you. We may also ask you (or have a service provider ask on your behalf) to participate in surveys seeking information or opinions related to our category of products and services.
A cookie is a text-only string of information that a website transfers to the cookie file of the browser on your computer’s hard disk, so that the website can remember certain information. Cookies cannot be used by themselves to identify you.
Two types of cookies are used on this Website, session cookies and persistent cookies.
Session cookies are temporary cookies that remain in the cookie file of your browser until you leave the site.
We use session cookies to:
We use persistent cookies to:
Note that most browsers are initially set to accept cookies. However, you have the ability to disable cookies if you wish, generally through changing the internet software browsing settings. It may also be possible to change the settings to enable acceptance of specific cookies. Please refer to the help section on your browser. If cookies are disabled you will be unable to access our Website.
For more information about cookies and how to disable them please visit allaboutcookies.org.
In the event that we offer the functionality to permit you to send messages regarding Website-related content to a friend or other persons through the Website, you may provide us with such persons’ email address so that we can facilitate your sending a message to such persons; provided, however, that we reserve the right to refuse to facilitate the message for any reason, including without limitation restrictions placed on this functionality by your jurisdiction or that of such person. We may retain that person’s email address but will use such email address only as described in this Privacy Policy and will not send additional promotional messages to your friend unless your friend registers with us (or has registered previously). Please note that any personal data you provide in connection with your request to send messages to such a person may be disclosed to them. By using this functionality, you confirm that all persons that you specify to receive messages have consented to receiving the emails from this Website that you request us to send.
We may have promotions or sweepstakes on our Website. When you enter a promotion or sweepstakes, we will ask for Personal Information about you. We will use this information for the purposes of administering the promotion or sweepstakes. We will also use and store this information for the purposes set forth under “Use of Personal Information” above unless you instruct us otherwise either through mechanisms provided with the entry form or by contacting us. Any additional uses for this information will be set forth in the applicable official rules, if any, of the promotion.
We may make available through the Website services such as message boards to which you are able to post information, photos, images and other materials. Please note that any information, photos, images or materials you disclose through such services or otherwise on the Website, becomes public information, and may be available to visitors to the Website all over the world and to the general public. In addition, when you choose to make a posting on such services, certain personal data will be available for other users to view. We urge you to exercise discretion and caution when deciding to disclose personal data, or any other information, on the Website. WE ARE NOT RESPONSIBLE FOR THE USE OF ANY PERSONAL INFORMATION YOU VOLUNTARILY DISCLOSE THROUGH PUBLICLY VIEWABLE PORTIONS OF THE WEBSITE.
The Website may contain links to third-party websites. These linked websites are not under our control, and we are not responsible for the privacy practices, the contents of any such linked website, any link contained in any linked website or any malware or malicious code that may be present on any such linked website. We provide such links only as a convenience, and the inclusion of a link on the website does not imply endorsement of the linked website by us. If you provide any personal data through any such third-party website, your transaction will occur on the third party’s website (not this Website) and the personal data you provide will be collected by and controlled by the privacy policy of that third party. We recommend that you familiarize yourself with the privacy policies and practices of any third parties. This Privacy Policy does not address the privacy or information practices of any third parties.
If you do not want to receive further email communications from us through the Website or its services, please follow the opt-out instructions in the email you receive from us. Otherwise, you may not get email communications you would otherwise expect to receive from us.
You can ask to review and correct the Personal Information that we maintain about you by sending a written request by email to us at privacyofficer@RightLabs.com.
This Website and all information that you submit through this Website is collected, stored, and processed in Canada or the United States. We use reasonable physical, electronic, and administrative safeguards to protect your Personal Information from unauthorized or inappropriate access. However, regardless of the effectiveness of our security measures, no security system is impenetrable. We cannot guarantee the security of our database, nor can we guarantee that information you supply will not be intercepted while being transmitted to us over the Internet. We ask that you do your part by, at a minimum, keeping any computer passwords you use to access the Internet or this Website strictly confidential.
We may modify and update this Privacy Policy from time to time. Changes in our Privacy Policy will be effective immediately. You should review this Privacy Policy on a regular basis. We will post at the top of this Privacy Policy the date that modifications were last made, which should alert you to any changes since your last visit to the Website. Your continued use of the Website is your agreement to the revised Privacy Policy.
For questions relating to RightLabs’ Privacy Policy, please contact our Privacy Officer as follows: (i) by postal mail to Privacy, RightLabs, Inc., 10436 81 Avenue NW Suite 300 Edmonton, AB, T6E 1X6, Canada, (ii) by email to privacyofficer@RightLabs.com, or by phone at (780) 424-3144, ext. 336.
III. Additional Information for Canadian Users of Our Website
One of the objectives of the Privacy Policy is to promote responsible and transparent practices in the management of personal information, in accordance with the provisions of the Personal Information Protection and Electronic Documents Act (Canada) (“PIPEDA”), the Personal Information Protection Act (Alberta), the regulations enacted thereunder, and any other applicable legislation or regulations.
Scope and Application
The ten principles of PIPEDA, which form the basis of the Privacy Policy, are interrelated and RightLabs shall adhere to the ten principles as a whole. Each principle must be read in conjunction with the accompanying commentary. The commentary in the Privacy Policy has been tailored to reflect personal information issues specific to RightLabs. The scope and application of the Privacy Policy are as follows:
Definitions as used in the Part III of the Privacy Policy
PRINCIPLE 1
ACCOUNTABILITY
RightLabs is responsible for personal information under its control and shall designate one or more persons who are accountable for RightLabs compliance with the following principles.
PRINCIPLE 2
IDENTIFYING PURPOSES FOR COLLECTION OF PERSONAL INFORMATION
RightLabs shall identify the purposes for which personal information is collected at or before the time the information is collected.
Further references to “identified purposes” mean the purposes identified in this Principle.
PRINCIPLE 3
OBTAINING CONSENT FOR COLLECTION, USE OR DISCLOSURE OF PERSONAL INFORMATION The knowledge and consent of a customer are required for the collection, use, or disclosure of personal information, except where inappropriate. In certain circumstances personal information can be collected, used, or disclosed without the knowledge and consent of the individual. For example, RightLabs may collect or use personal information without knowledge or consent if it is clearly in the interests of the individual and consent cannot be obtained in a timely way, such as when the individual is seriously ill or mentally incapacitated. RightLabs may also collect, use or disclose personal information without knowledge or consent if seeking the consent of the individual might defeat the purpose of collecting the information, such as in the investigation of a breach of an agreement or a contravention of a federal or provincial law. RightLabs may also use or disclose personal information without knowledge or consent in the case of an emergency where the life, health or security of an individual is threatened. RightLabs may disclose personal information without knowledge or consent to a lawyer representing RightLabs, to collect a debt, to comply with a subpoena, warrant or other court order, or as may be otherwise required or authorized by law.
PRINCIPLE 4
LIMITING COLLECTION OF PERSONAL INFORMATION
RightLabs shall limit the collection of personal information to that which is necessary for the purposes identified by RightLabs. RightLabs shall collect personal information by fair and lawful means.
PRINCIPLE 5
LIMITING USE, DISCLOSURE, AND RETENTION OF PERSONAL INFORMATION
RightLabs shall not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required by law. RightLabs shall retain personal information only as long as necessary for the fulfillment of those purposes.
PRINCIPLE 6
ACCURACY OF PERSONAL INFORMATION
Personal information shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.
PRINCIPLE 7
SECURITY SAFEGUARDS
RightLabs shall protect personal information by security safeguards appropriate to the sensitivity of the information.
PRINCIPLE 8
OPENNESS CONCERNING POLICIES AND PRACTICES
RightLabs shall make readily available to customers specific information about its policies and practices relating to the management of personal information.
PRINCIPLE 9
CUSTOMER AND EMPLOYEE ACCESS TO PERSONAL INFORMATION
RightLabs shall inform a customer of the existence, use, and disclosure of his or her personal information upon request and shall give the individual access to that information. A customer shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.
PRINCIPLE 10
CHALLENGING COMPLIANCE
A customer shall be able to address a challenge concerning compliance with the above principles to the designated person or persons accountable for RightLabs compliance with the RightLabs Privacy Policy.
California Do-Not-Track Disclosure
At this time, the Website is not set up to honor web browser do-not-track settings. Do-not-track is a privacy preference that users can set in their web browsers. When a user activates the do-not-track settings in browsers that offer this setting, the browser sends a message to websites requesting them not to track the user. For more information about do-not-track matters, please visit www.allaboutdnt.org.
Information on Marketing Disclosures
California Civil Code Section 1798.83 permits our users who are California residents to request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us at Privacy, RightLabs, Inc., #217-8008 104 Street, Edmonton SAB, T6E 4E2 CANADA or by email to privacyofficer@RightLabs.com.
In addition to the information provided elsewhere in this Privacy Policy, persons (“GDPR Data Subjects”) who are residents of the member countries of the European Union (“EU”) or other data subjects covered by the EU’s General Data Protection Regulation, (EU) 2016/679 (the “GDPR”), have certain additional privacy rights under applicable law. The following provisions of this Privacy Policy provide an overview of these additional rights and related information.
Our Commitment
RightLabs embraces the approach to privacy protection reflected in the GDPR, giving our Website users a greater say in what happens with their data. Please contact our data protection officer at either Privacy, RightLabs, Inc., #217-8008 104 Street, Edmonton SAB, T6E 4E2 CANADA or by email to privacyofficer@RightLabs.com, if you have any questions about any matters related to our GDPR compliance.
Legal Bases for Processing Personal Information of European Union Residents or Other GDPR Data Subjects
If you are a GDPR Data Subject, RightLabs may rely on one or more of the following legal bases (or other available legal grounds) when processing your personal information, depending on the circumstances:
Disclosures to Third Parties
If you are a GDPR Data Subject, your personal information will not be disclosed to third parties except where it is necessary for fulfillment of RightLabs’s obligations to you or where RightLabs is obliged or permitted to do so by law (including, without limitation, through the terms of any agreement RightLabs may have with you), or where RightLabs makes disclosures that are otherwise consistent with the uses described in this Policy.
RightLabs may also disclose any information (including personal information) relating to you to law enforcement authorities or any regulatory or government authority in response to any request including requests in connection with the investigation of any suspected illegal activities.
RightLabs reserves the right to transfer any personal information RightLabs has about you in the event RightLabs sells or transfers all or a portion of our business or assets, or merges with another organization. Should such a sale, transfer or merger occur, RightLabs will use reasonable efforts seeking to require that the transferee uses personal information you have provided to RightLabs in a manner that is consistent with this Policy.
RightLabs will not sell, resell or lease your personal information to any third parties but RightLabs may, if required for the purpose(s) for which your personal information was collected and processed, share it with RightLabs partners and/or service providers to enable them to provide their services to RightLabs or to you, as applicable. The foregoing are in addition to the other uses described elsewhere in this Policy.
Security of Personal Information of European Residents or Other GDPR Data Subjects
RightLabs has policies and technical and organizational measures in place which are intended to safeguard and protect your personal information against unauthorized access, accidental loss, improper use and disclosure. However, you should be aware that information transmitted over the internet is not completely secure because of the nature of the internet and that systems and measures used to secure information are not flawless. For these reasons, although RightLabs will use reasonable efforts to protect your personal information, RightLabs does not warrant the security of personal information transmitted to RightLabs or stored by RightLabs, and personal information that is transmitted to RightLabs by you electronically is done at your own risk.
Retention of Personal Information of European Residents or Other GDPR Data Subjects
RightLabs’s policy is to retain your personal information only for as long as is necessary to fulfill the purposes for which RightLabs collected such personal information, including for the purposes of satisfying any professional, legal, accounting or reporting requirements to which RightLabs is subject. To determine the appropriate retention period for personal information, RightLabs considers the scope, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of the personal information, the purposes for which RightLabs collected and processed your personal information and whether RightLabs can achieve those purposes through other means, and any applicable legal and professional requirements.
Your Rights as a European Resident or Other GDPR Data Subject
If you are a GDPR Data Subject, you have a number of rights concerning your personal information that RightLabs holds and uses, including the following:
You may exercise any of the above requests in writing, or request that RightLabs stop using your personal information for marketing purposes by contacting, us by postal mail at Privacy, RightLabs, Inc., #217-8008 104 Street, Edmonton SAB, T6E 4E2 CANADA, or by email at privacyofficer@RightLabs.com.
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