Personally, identifiable information, (“Personal Information”), is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context.
By using the Website (as clearly described on the Website) and the Services you consent to our collection and use of your Personal Information as described herein, and consistent with applicable data protection laws.
The Information that we collect about you is controlled by 8810931 Canada Inc., which is headquartered in Montreal, Canada.
A – INFORMATION COLLECTED
Depending on how you use our Website and Services, we may collect, use, share and secure different kinds of Information. The types of Personal Information we collect, with your consent, are detailed below.
What information do we collect?
We collect information you choose to provide to us. The Personal Information that you provide directly to us will be apparent from the context in which you provide the data.
When you browse our Website or use the Services, we receive Information that helps us learn about your browser and operating system. This may include such data as your IP address and domain name, the pages you visit on the site, date and time of your visit, the files you download, the URLs from the websites you visit before and after navigating to the Website, your software and hardware attributes, your general geographic location and certain cookie information (see below).
Any other Information you consent to provide on our Website will also be stored. For example, if you join our email list, your name and email address will be stored, and if you register on our Website, we will use the Information you provided on our Website in order to contact you regarding the Services.
Only if you use a credit card to pay for Services on our Website, and consent to providing your credit card information in order to process such transaction, a third-party (Stripe) will collect payment information from you.
Use of the Service by our Customers
B – WHAT DO WE DO WITH YOUR INFORMATION?
We use Information we collect to help our Services create a better experience for you. Collecting Information about how you use Services helps us provide you with better service, including understanding which features are the most interesting to you, so that we are able to improve them.
We use your Information to create your account, to respond to your questions or requests concerning the Website or the Services offered by Croogloo, to provide you Services you have ordered, to communicate with you about Service you have purchased, to improve and support our Website and Services, to market our Services and offer you additional Services, to bill you, to fulfill the terms of any agreement you have with us, to fulfill your requests for our Services or otherwise complete a transaction that you initiate, to send you information about our Services, to improve your user experience and the quality of our products and services. We also use the Information to the extent necessary to enforce our Website and Services terms of service and to prevent imminent harm to persons or property and to comply with legal and/or regulatory requirements. Certain Information may be used for anti-fraud and anti-theft purposes. We will use your Information to send out important notices, confirmations, and similar operational communications.
We use the non-personal Information that we collect for such purposes as: counting and recognizing visitors to the Website; analyzing how visitors use the Website and various Website features; improving the Website and enhancing users’ experiences with the Website and Services; creating new products and Services or improving our existing Services; enabling additional website analytics and research concerning the Website; and managing our business, and to comply with legal and/or regulatory requirements. Croogloo may link non-personal information gathered using cookies and web beacons with Personal Information, but in such event, Croogloo will treat the combined information as Personal Information.
We may send you emails about our Services and other updates, promotions and Croogloo advertisements, and other topics that are likely of interest to you if you consent to the provision of this type of material by registering on our Website or signing up for a mailing list. Although we hope you will find our promotional emails of interest, you may opt-out of receiving them.
We may link non-personal Information gathered using cookies with Personal Information, but we will treat the combined information as Personal Information. We may combine Personal Information collected through the Website and/or the Services with other Information that we or third parties collect about you in other contexts, such as our communications with you via email or phone, or your customer service records. We use this linked Information for internal use any linked Information for our own advertising and marketing purposes, we do so only after it has been converted to anonymized or aggregated form.
From time to time, Croogloo may also share anonymized and aggregated information about the Website and Services, such as by publishing a report. With respect to the Services, more information on this is contained in our agreement with our customers.
How long do we keep your information?
How long we keep Information depends on the type of Information:
- If you have consented to receiving marketing communications from us, we will retain your Personal Information for a reasonable period of time from the date you last provided consent, unless you request that we remove it.
- If we receive Information derived from cookies or other tracking technologies, we will retain that Information for a reasonable period of time from the date it was collected.
At the conclusion of our use of data, we will either delete or anonymize your Information or, if that is not possible, then we will securely store your information and isolate it from any further use until deletion is possible.
If you provide information to a customer of ours as part of their use of Service, that customer decides how long to retain that Personal Information. If the customer terminates their access to our Service, they may receive access to Personal Information stored within the Service pursuant to our agreement with them.
Your Personal Information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems and are required to keep the information confidential.
To protect your personal Information, we take reasonable precautions and follow industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered, or destroyed.
Unfortunately, even with these measures, we cannot guarantee the security of Personal Information. BY using our Website and Services, you acknowledge and agree that we make no such guarantee.
C – CONSENT, DATA CORRECTION AND REMOVAL
Croogloo acknowledges that individuals have the right to access the Personal Information that we maintain about them.
How do you get my consent?
How do I modify Information or withdraw my consent for Personal Information collected via the Website?
You may ask to be removed from our email list by emailing us here: [email protected]
What if I have questions about consent or your use of my Information?
If you have questions at any time regarding the continued collection, use, storage, or disclosure of your Information, or if you would like to correct, amend, or delete inaccurate data, you may contact us at [email protected]
Where the processing of your Personal Information is based on your previously given consent, you have the right to withdraw your consent at any time. You may also have the right to object to the processing of your Personal Data on grounds relating to your particular situation.
D – HOW DO WE SHARE PERSONAL AND NON-PERSONAL INFORMATION WITH THIRD PARTIES?
We share information with other parties for a variety of purposes, as described below:
Third-Party Service Providers
We use third-party service providers to help us manage and improve the Website and our Services. We may share Information with our contracted service providers so that these service providers can provide services on our behalf. These service providers are authorized to use Information only as necessary to provide the requested services to us.
You may request information about service providers at any time. If you would like Croogloo to stop providing your Personal Information to any service provider, please contact us at [email protected]
In particular, the Website and Services uses Google Analytics to help collect and analyze certain information for the purposes discussed above. Google Analytics may set and/or access a cookie and/or web beacon.
Third-party payment processor – Stripe
We use a third-party payment processor to process credit card payments made to us. In connection with the processing of such payments, we do not retain any Personal Information or financial information such as credit card numbers. Rather, all such information is provided to our third-party processor.
We are not responsible for the performance of any third-party credit card processing or third-party payment services.
We may be legally required to disclose your information if we believe it is reasonably necessary, in our sole discretion, in order to (i) comply with legal process or other legal requirements of any governmental authority, (ii) potentially mitigate our liability in an actual or potential lawsuit, (iii) establish, protect or exercise our legal rights or protect or defend our property, (iv) protect the legal rights of property of others, (v) protect the safety of our customers, users, employees or others, (vi) facilitate the financing, securitization, insuring, sale assignment, bankruptcy, or other disposal of all or part of our business assets.
With your consent, mobile applications may provide us with information related to your use of the mobile application services, information regarding your computer systems, and information regarding your interaction with mobile applications, which we may use to provide and improve the mobile application Services.
E – COOKIES AND WEB BEACONS
The Website or emails you receive from Croogloo may use an application known as a “web beacon”. A web beacon is an electronic file that usually consists of a single-pixel image. It can be embedded in a web page or in an email to transmit information, which could include personal information. For example, it allows an email sender to determine whether a user has opened a particular email.
If you would like more information about what cookies and web beacons we use and how they are used, please contact us at: [email protected]
F – SPECIAL NOTICE TO INTERNATIONAL VISITORS AND CUSTOMERS
Information about how and when we process your personal information
- We process your Personal Information with your consent when you register on our Website; and when you agree to receive online direct marketing from us.
- We process your Personal Information as required by applicable law. Applicable law may require us to process your information: for tax purposes, to prevent/detect fraud, and in disclosures to law enforcement and other regulatory or government agencies as required by law.
- We also process your Personal Information when it is in our legitimate interest to do so, and the legitimate interest is not overridden by your data protection rights. Here are some examples of our legitimate business interests:
- Developing and maintaining relations with our customers and partners;
- Understanding how our customers use our Services and the website;
- Improving our Services;
- Understanding and responding to customer feedback;
- Researching and analyzing the Services our customers want;
- Securing our business and services
When we ask you to supply us with Personal Information you will see whether the information we are asking for: (i) must be supplied so that we can provide Services, (ii) must be supplied because it is required by law, or (iii) is optional, and if optional, what happens if you do not provide the information, you will not be added to our email list.
Where applicable law requires us to ensure that an international data transfer is governed by a data transfer mechanism, we use the following mechanisms” EU Standard Contractual Clauses with a data recipient outside the EEA (as permitted under GDPR), we will ask for your consent or we will rely on the Privacy Shield.
EU-US and SWISS-US Privacy Shield Frameworks
We acknowledge that you have a right to access your Personal Information. We have no direct relationship with individuals whose Personal Information is processed as a result of a customer inputting content or data related to some who is not a user of our Service into our Service. Please note that if the data is provided by a customer for use with our Service, that customer controls the data and is responsible for correcting, deleting, or updating the Information they use with the Service. If you make a request to us to remove this data, we will notify our customer, and also respond to you. Please also contact the customer directly, yourself. Please note that we are not responsible for how our customers use the data they store within the Service.
In certain situations, we may be required to disclose personal data in response to lawful request by public authorities, including to meet national security or law enforcement requirements.
Croogloo’s accountability for personal data that it receives in the United States under the Privacy Shield and subsequently transfers to a third-party described in the Privacy Shield Principles. In particular, Croogloo remains liable under the Privacy Shield Principles if the third-party agents that it retains to process transfer data on Croogloo’s behalf process such personal data in a manner inconsistent with the Privacy Shield Principles, unless Croogloo can prove that it is not responsible for the event giving rise to the damage.
Your rights and contact information
You have the right to:
- Ask us for a copy of your Personal Information
- Correct Personal Information, erase Personal Information or transfer it to other organizations at your request
- Object to some processing and, where we have asked for your consent to process your personal information, to withdraw this consent.
- Object to some processing where we have a legitimate interest in processing
- To restrict processing in certain circumstances
G – MODIFICATIONS AND CONTACT US
If you would like to: access, correct, amend or delete any Personal Information we have about you, register a complaint, or simply want more information, contact us at [email protected]