It is always a User’s choice whether or not to provide Personal Information. However, if a User chooses not to provide requested Personal Information, that User will not be able to use certain features of the Services. We set out in detail below the information that we collect about Users and Users’ use of our Services. Ciirve does not collect on its own behalf things like protected health information, financial information, date of birth, social security or other government-issued identification number, and other sensitive personal information.3. Children
We may collect, use, store and transfer different kinds of personal data about Users which we have grouped together follows:
We also collect, use and share Non-personalized data called “Service Data” such as statistical or demographic data for any purpose. Service Data may be derived from User’s Personal Information but is not considered personal information in law as this information does not directly or indirectly reveal User’s identity. For example, we may aggregate User’s Usage Data to calculate the percentage of users accessing a specific Website feature. Other than health information, we do not collect any Special Categories of Personal Data about Users (this includes details about User’s race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about User’s health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.5. How Is User’s Personal Information Collected
We use different methods to collect data from and about Users including through:
We have set out below, in a table format, a description of all the ways we plan to use Users’ Personal Information.
|Purpose/Activity||Type of Data|
|To deliver the Services to Users (including by recognizing users across the devices they use, and providing, maintaining, tailoring and improving website and services)||
|To register Users accounts on the Services||
|To administer and protect our business and this the Services (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||
|To use data analytics to improve our Services, customer relationships and experiences and to personalize our Services||
|To make suggestions and recommendations to Users about Services that may be of interest to Users and to provide Users with information, products or services they request||
To improve our Services including:
We may also disclose User’s Personal Information:
Upon request, Ciirve will provide Users with information about whether we hold any of User’s Personal Information. Ciirve enables Users with the ability to access and correct Personal Information we have collected. If Users have any concerns or suspect unauthorized activities associated with User’s account, please contact us at firstname.lastname@example.org. We will respond to User’s request within a reasonable timeframe, and in any event within 30 days of receipt of request. Ciirve acknowledges that Users have the right to access, update, revoke permission to process, or request the deletion of User’s Personal Information. Any such query can be directed to Ciirve’s Chief Privacy Officer at email@example.com. If requested to remove data under either scenario, we will respond within a reasonable timeframe.9. Security and Enforcement
The security of User’s Personal Information is important to us. We use security safeguards appropriate to the sensitivity of the information to ensure that User’s Personal Information is stored and maintained in a secure environment. Ciirve exercises managerial and technical safeguards designed to protect against the loss or unauthorized use or disclosure of Personal Information belonging to our Users. These safeguards include encryption, malware protection, logical and physical access controls, and detection of social engineering attacks.
Ciirve will keep User’s Personal Information for as long as it remains necessary for the identified purposes set out below or as required by law, which may extend beyond the termination of our relationship with User. Users acknowledge and agree that if User request that User’s name be removed from our databases, it may not be possible to completely delete all User’s Personal Information due to legal constraints.
|Data Type||Retention period||Reason|
|Identity, Contact and Profile data||Subscription term and 3 months after account termination||To provide the Services to you during the subscription term.|
|Technical and Usage data||3 years after account termination||To provide the Services to you during the subscription term and to protect against fraud.|
|Class recordings||2 years after recording||For compliance and risk management purposes|
As Users navigate through and interact with our Website, App and Services, we may use automatic data collection technologies to collect certain information about User’s equipment, browsing actions and patterns, location, and workplace usage patterns, including:
Cookies are small files saved to the User's computer’s hard drive that track, save and store information about the User's interactions and usage of the Website. This allows the Website, through its server, to provide the Users with a tailored experience within the Website.
Users are advised that if they wish to deny the use and saving of cookies from the Website on to their computers hard drive they should take necessary steps within their web browsers security settings to block all cookies from the Website and its external serving vendors.
Other cookies may be stored to your computer’s hard drive by external vendors when the Website uses referral programs, sponsored links or adverts. Such cookies are used for conversion and referral tracking and typically expire after 30 days, though some may take longer. No Personal Information is stored, saved or collected.13. Payment Processing
When you use the Services, we may ask you to pay for the use of the Services. Your payment information is processed by our third party payment service providers, and not by Ciirve. Ciirve does not store or have access to your financial information such as credit card numbers or bank numbers.14. Links
The Service may contain third party links, including sponsored links and adverts.
We take no responsibility for any external links or the websites or content to which they may direct Users. Users should click on external links at their own risk. We cannot be held liable for any damages or implications caused by visiting any external links mentioned.15. Transfers and disclosures of Data
Ciirve’s headquarters in Canada is our primary location for business operations, but may process or transfer data in or to other jurisdictions in the course of providing the Services.
For example, regarding normal business operations, Ciirve may engage a third-party to support our data storage, data processing, billing, support services, information technology, or mailings on our behalf, which third party’s facilities may be located in another jurisdiction.
We may also disclose User’s Personal Information as required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect User’s safety, or the safety of others, investigate fraud, or respond to a government request.
Ciirve Chief Privacy Officer
Ciirve Technologies Inc.
1923 East 7th Avenue, Vancouver, B.C. V5N 1S3, Canada
Updated: April 30, 2020