Effective date: June 15th, 2020
Cinchy Inc. ("Cinchy", "we", "us" or "our") takes steps intended to meet privacy principles and requirements with respect to personal information under applicable privacy legislation. The purpose of this statement is to inform our customers and other individuals we deal with ("you" or "your") how we collect, use, disclose and protect your personal information.
Personal information is information about an individual through which that individual can be identified, as more particularly described under applicable privacy legislation. This statement does not apply to information about our employees or to information that is not personal information.
Cinchy and its agents and representatives collect personal information in a number of circumstances in the course of serving our customers by creating business outcomes using data collaboration methodology.
Personal information we collect may include:
Cinchy generally uses personal information for the following purposes:
Cinchy discloses personal information in the following circumstances:
We may also provide your Personal Information to a third party in connection with a merger or acquisition of Cinchy, either in part or in whole, or the assignment or other transfer of the Site. In such event, such third party will either:
In addition to the above, personal information may be disclosed to affiliated contractors, who provide services to Cinchy for product development, testing, internal audit, management, billing or administrative purposes including defending and bringing legal actions.
Cinchy may transfer personal information to outside agents or service providers that perform services on our behalf, for example server hosting, professional service, support, billing, marketing, or similar services, or otherwise to collect, use, disclose, store or process personal information on our behalf. Some of these service providers or affiliates may be located outside of Canada, including in the United States or India, and your personal information may be collected, used, disclosed, stored and processed in the United States or elsewhere outside of Canada for the purposes described in this Privacy Statement. Reasonable contractual measures will be taken to protect your personal information while processed or handled by these service providers.
Personal information may be used by Cinchy and disclosed to parties connected with the proposed or actual financing, securitization, insuring, sale, assignment or other disposal of all or part of Cinchy or our business or assets, for the purposes of evaluating and/or performing the proposed transaction. These purposes may include, as examples:
Cinchy may disclose your personal information as necessary to meet legal, regulatory, industry self-regulatory, insurance, audit, and security requirements, and as otherwise with your consent or as permitted or required by law (including as required by applicable Canadian and foreign laws applicable to Cinchy or our agents and service providers, and including lawful requirements to disclose personal information to government authorities in those countries).
When you use the Site, create an account to use the Site, use our Platform, or otherwise communicate with us (e.g. via email), Personal Information will be collected by the Site or Platform. The Personal Information collected is as follows:
Note that any information that you post in an Interactive Area might be read, collected, and used by others who access it. You may take down any information you have added to the Interactive Areas at any time. To request removal of your personal information from an Interactive Area, please contact us at privacy@cinchy.com.
If a Cinchy customer uses the software to analyze personal data in their databases, Cinchy will process the categories of personal data analyzed, which may include special categories of data as determined by the customer, including without limitation factors specific to the individual's physical, physiological, genetic, mental, economic, cultural or social identity.
Cookies are small data files that are placed on users' devices to monitor how users interact with websites and other online services. Pixel tags, also called web beacons or single-pixel gifs, tag a graphic on a web page or in an email message that tracks pages viewed or email messages opened. Logs are continuous digital records of events and interactions that occur on a website. Cookies, pixel tags, and/or logs can be used to identify your IP address, browser type, domain name, and specific web pages through which you click and/or email messages you open.
Cinchy and our service providers may use cookies, pixel tags, and/or logs because they:
Most web browsers allow you to erase cookies on your computer, block cookies from your computer, or notify you when a cookie is stored on your computer. If you choose to disable or otherwise block certain cookies, you may be unable to use, or experience decreased functionality with, parts of the Site. Your browser may also support functions to block or restrict pixel tags.
When you visit or log in to our website, cookies and similar technologies may be used by our online data partners or vendors to associate these activities with other personal information they or others have about you, including by association with your email or home address. We (or service providers on our behalf) may then send communications and marketing to these email or home addresses. You may opt out of receiving this advertising by visiting https://app.retention.com/optout.
Consent to the collection, use, and disclosure of personal information may be given in various ways. Consent can be expressed (for example, orally, electronically, or on a form you may sign describing the intended uses and disclosures of personal information) or implied (for example, when you provide information necessary for a service you have requested).
You may provide your consent in some circumstances where notice has been provided to you about our intentions with respect to your personal information and you have not withdrawn your consent for an identified purpose, such as by using an "opt out" option provided, if any. Consent may be given by your authorized representative (such as a legal guardian or a person having a power of attorney).
Generally, by providing us with personal information, we will assume that you consent to our collection, use, and disclosure of such information for the purposes identified or described in this privacy statement, if applicable, or otherwise at the time of collection.
You may withdraw your consent to our collection, use, and disclosure of personal information at any time by emailing privacy@cinchy.com, subject to contractual and legal restrictions and reasonable notice. Note that if you withdraw your consent to certain uses of your personal information, we may no longer be able to provide certain of our products or services.
Note also that where we have provided or are providing services to you, your consent will be valid for so long as necessary to fulfill the purposes described in this Privacy Statement or otherwise at the time of collection, and you may not be permitted to withdraw consent to certain necessary uses and disclosures (for example, but not limited to, maintaining reasonable business and transaction records, disclosures to Canadian and foreign government entities as required to comply with laws, and reporting on credit information after credit has been granted, if applicable).
Cinchy collects, uses, and discloses your personal information with your consent, except as permitted or required by applicable law. We may be required or permitted under statute or regulation to collect, use or disclose personal information without your consent, for example, to comply with a court order, to comply with local or federal regulations, or a legally permitted inquiry by a government agency, or to collect a debt owed to us.
We take reasonable steps to protect your personal information using physical, electronic, or procedural security measures appropriate to the sensitivity of the information in our custody or control, which may include safeguards to protect against loss or theft, as well as unauthorized access, disclosure, copying, use or modification. Authorized employees, agents, and mandataries of Cinchy who require access to your personal information in order to fulfill their job requirements will have access to your personal information.
Cinchy may establish and maintain a file of your personal information for the purposes described above. If you wish to request access or correction of your personal information in our custody or control, you may write to the privacy email address, privacy@cinchy.com, attention Privacy Officer. Your right to access or correct your personal information is subject to applicable legal restrictions. We may take reasonable steps to verify your identity before granting access or making corrections.
If you wish to make inquiries or complaints or have other concerns about our personal information practices, you may:
This Privacy Statement may be revised from time to time. If we intend to use or disclose Personal Information for purposes materially different than those described in this statement, we will make reasonable efforts to notify affected individuals, if necessary, including by revising this Privacy Statement.
If you are concerned about how your personal information is used, you should contact us as described above to obtain a current copy of this statement. We urge you to request and review this Privacy Statement frequently to obtain the current version.
Your continued provision of Personal Information or use of our services following any changes to this Privacy Statement constitutes your acceptance of any such changes.
This privacy statement is effective as of June 15th, 2020.