Effective Date: 2021-02-23
This policy describes how Data Broom, part of ebCard Inc. (“ebCard” or “we”) collects, processes, uses and shares personal information and personal data about users of the ebCard Platform, including the ebCard mobile application (the "Platform") and visitors of the ebCard website (the “Website”).
In this policy, the term personal data refers to information that relates to an individual who is identifiable.
The contact details of the personal data controller under this policy are as follows:
7525 Av. Mountain Sights
Montreal, QC H4P0A4
Basis of Data Processing
To (1) enable users to use the Platform and the services offered through the Platform and (2) operate the Website, we must collect and process personal data about individuals. Our processing of personal data is mainly based on the following principles:
- We process personal data on behalf of our customers as a service provider or data processor. In that case, our customer is responsible for obtaining all necessary authorizations and consents from the data subjects.
- We must process some personal data to provide our services and allow users to use the Platform.
- We may process some personal data because our clients or we have obtained specific consent from relevant individuals. Individuals may withdraw their consent at any time, and we will stop personal data processing based on such consent.
- When necessary for our legitimate interests and our customers, we process some personal data when the processing does not violate individuals’ fundamental rights.
Data We Collect
Information that comes from you
We collect the information you provide to us (for example, by completing a form) through the Platform interface, the Website or otherwise. This information may include:
- Your first and last name;
- Your email address;
- Your company name
- Your professional phone number
- Your company address
Data Collected Automatically
We collect information automatically when visitors browse the Website or when customers use the Platform. This information is saved for each interaction with the Platform and includes information about devices used to access and data about your interactions with the Platform, in particular:
- The operating system and identification number of your mobile device;
- The make and model of your mobile device
- The version of the Platform in use;
- The operating language of your computer;
- The IP address from which your device accesses the Platform or the Website;
- The country, state, city, and zip code where your device is located;
- Pages visited, actions are taken, the number of connections to the Platform, the date of the connections to the Platform.
Data Collected from our Customers
We collect personal data that is uploaded to the Platform by our customers. Our customers warrant that they are authorized to process personal data uploaded to the Platform according to this Policy.
Data from Analytical Tools
When you access the Platform, we collect data provided by analytics tools such as Google Analytics.
Data from Social Networks
We collect information from sites or social networking platforms (Facebook, LinkedIn, Twitter, YouTube, Google+, etc.) when users or visitors interact with profiles belonging to us. These sites or platforms are also governed by their own policies regarding personal data, which may differ from ours and may be applicable.
How We Use Personal Data
We process personal data collected through the Platform for the purposes described below. Some processing is subject to specific consent, while other processing is necessary to provide services. It is based on the pursuit of legitimate interests or is done according to our customers' instructions.
Contacting our Customers
We use the personal data provided by customers’ representatives to contact them about their use of the Platform. We abide by applicable regulations for unwanted electronic communications. If you no longer wish to receive electronic communications from ebCard, you can notify us at any time at the following address: firstname.lastname@example.org.
Customizing Our Services and the Platform
We use data collected automatically to personalize user experience on the Platform. We may modify the appearance and the features of the Platform or the Services according to users’ preferences or habits.
Validating Contact Information
We may use personal data uploaded to the Platform by our customers to perform validity checks on contact information. This process seeks to determine inconsistencies in similar contact information from different customers but will never lead to the disclosure of one customer’s contact information data to another customer.
We may use personal data to validate contact information against publicly available data. However, we will not aggregate publicly available personal data with customer data.
We use data collected through the Platform and data collected from analytics tools to monitor the Platform's use generally, prevent misuse of the Platform, identify problems or bugs in the Platform, and determine which features we should improve.
We process personal data collected through the Platform to fulfill our legitimate interests and our customers, including improving our services and validating the contact information provided by our customers.
We take privacy seriously. That is why personal data processing based on our legitimate interests or that of our customers never involves targeted monitoring or communicating specific personal data about identifiable individuals to third parties.
How do we Store Personal Data?
We keep some personal data on behalf of our customers, which may delete their platform's data at their convenience.
We keep personal data that our customers’ representatives provide until we are asked to destroy it.
Personal data is stored electronically on our servers in Canada and the US, depending on client location. Our hosting provider operates these servers, Amazon Web Services (AWS), which undertakes in writing to keep personal data confidential.
Personal data collected about individuals located outside of Canada is transferred to Canada. Canada is recognized as an adequate jurisdiction for the transfer of personal data from the European Union.
How Personal Data Is Protected
Our personal data is hosted by our hosting provider, Amazon Web Services (AWS), which agrees to use industry-standard security measures to maintain data integrity and confidentiality.
Our employees and service providers are aware that the personal data collected through the Platform is confidential and are informed about the appropriate security measures to prevent unauthorized access to personal data.
How Personal Data is Disclosed
We only share personal data as described in this policy or when we have the consent of the affected individuals. Personal data may be disclosed to the categories of recipients described below for the purposes mentioned.
Collected personal data is only available to our officers and employees who must access it for the purposes described in this policy.
We may also disclose personal data to third parties if the law expressly authorizes or requires such disclosure or if we are ordered to do so by a competent authority. We may disclose personal data in the context of court proceedings, if necessary, to protect our rights or those of our users.
Sale of Business
If the sale or restructuring of all or part of our business is envisioned, we may disclose collected personal data to the persons or organizations involved before and after the transaction, whether or not it takes place. In such a case, these persons or organizations undertake to keep disclosed personal data confidentially and use the same exclusively to evaluate the feasibility of the opportunity of the proposed transaction and this policy.
What are your Rights to your Personal Data?
As an individual, you may exercise rights about your personal data held by ebCard. However, in the vast majority of cases, we process personal data on behalf of customers and per their instructions, and individuals should contact our customers directly about their personal data.
Access your data
Customers’ representatives may have access to personal data that they have personally provided to us by accessing their account through the Platform.
To access the personal data that we hold about you or rectify personal data incorrectly, you may request in writing to the following address: email@example.com or the data controller's address at the beginning of this policy.
We will respond to your request promptly (within 30 days of receipt), allowing you to access your personal data under our control. When required by law, we will provide your data in a portable, machine-readable format.
We may direct individuals to our customers when we are processing personal data on behalf of a customer.
Withdrawal of Consent
If you wish to withdraw your consent to your personal data processing, please notify us in writing at firstname.lastname@example.org.
Individuals should contact our customers directly when we are processing their personal data on behalf of a customer.
If you are a customer representative, it is impossible to stop all processing of your personal data and continue using the Platform. The only way to stop all processing of your personal data is to stop using the Platform.
Objection to processing
In certain circumstances, depending on your place of residence, you may have the right to object to your personal data processing based on your legitimate interests. You may object to the processing of your data in writing at email@example.com.
You may request the erasure of personal data that we hold about you in writing at firstname.lastname@example.org. We will respond to your request as soon as possible (within 30 days of receipt).
We may hold your personal data on behalf of our customer, in which case you must refer to our customer to request the erasure of your personal data.
If you continue to use the Platform after your personal data has been erased, we will continue to collect some data about you.
If you reside in the European Union, you have the right to complain about the processing of your personal data with a supervisory authority responsible for protecting privacy. The competent authority may vary depending on your country of residence.
If you reside outside of the European Union, this policy shall be governed by the laws applicable in Canada, and the Canadian authorities shall have exclusive jurisdiction to hear any complaint or proceedings.
We reserve the right to verify the identity of individuals requesting access to personal data. Any information we use to perform the verification will not be used for any other purpose.
Updates to This Policy
We may update this policy from time to time to reflect changes in our personal data management practices. If this policy is modified, the new policy will be available through the Platform and on our website at the following: www.data-broom.com/privacy.
For any additional information concerning your personal data processing, you may contact us using the contact information at the beginning of this Policy.
- Basis for Data Processing
- Data We Collect
- How We Use Personal Data
- How do we Store Personal Data?
- How Personal Data is Protected
- How Personal Data is Disclosed
- What are your Rights about your Personal Data?
- Updates to This Policy
- Additional Information