PRIVACY POLICY

Last updated: June 10, 2021

The Essafin Privacy Policy describes the privacy practices of Essafin’s software and website(s). Your relationship is with Essafin Logic and the laws of The Province of British Columbia and the Country of Canada apply.

Please note that in order to use our software and website(s), you authorize Essafin to transfer your personal information across provincial borders, national borders and to other countries where Essafin and its partners operate. The privacy protections and rights of authorities to access your information in these countries may not be equivalent to those in your country. We will only transfer your personal information to these countries where permitted to do so by law and we will take steps intended to ensure that your personal information continues to receive appropriate protections. 

If the content or information that you store on Essafin software or website(s) contains personal information of other individuals, you must be legally permitted to share the personal information with Essafin. 

Summary of Key Points

• Where your consent is required, we will obtain your permission before (i) sending you news and promotional material about Essafin; (ii) accessing information stored on your device relating to your use of, and engagement with, website(s) and software and crash reports; and (iii) using automated systems to analyze your content. You can withdraw your consent to such activities at any time.
  
  

• This policy explains when we process personal information for our legitimate interests. You can ask us to stop processing this information.
  
  

• We use your personal information to enable you to register with Essafin and to provide you with our website(s) and software, and other products or services that you request. 

• We provide interactive features that engage with social media sites, such as Linkedin. If you use these features, these sites will send us personal information about you.
  
  

• We use cookies and other technologies to track the use of our website(s) and software.
  
  

• There are several places within Essafin’s website(s) and software that allow you to post comments, upload pictures, or submit content which will be publicly available where you choose to participate in these activities. We also disclose personal information to other companies in the Essafin family and with advertising and sales partners consistent with your choices. We also share information with third parties we engage to process information on our behalf or when such sharing is required by law, or in certain other situations.

What does this privacy policy cover?

This privacy policy describes how Essafin (also referred to as "we," "us" or "our") will make use of your information in the context of:

• Essafin website(s); web-based services such essafin.io and www.essafinlogic.com (together referred to as "website(s)");

• Desktop software and mobile software (both referred to as "software") that include a reference to this policy; and

• Essafin’s marketing, sales, and advertising practices. 
  
  

Please note that website(s) and software provided by some companies working with Essafin may operate under their own privacy policies until their privacy practices are integrated with Essafin's privacy practices.

What information does Essafin Logic collect about me?

Essafin ID, registration, and customer support

When you register to use an Essafin software or website(s), create an Essafin ID, or contact us for support or other offerings, Essafin collects information that identifies you. This includes:

• Name;

• Company name;

• Email address;

• Telephone number;

• Address;

• Country;

• Mobile Device Type
  Desktop Device Type

• Payment/billing information (where an software or website(s) is 'paid for');

• Eligibility information;

• Types of software and website(s) of interest; and

• Content of customer support communications.

To help keep our databases current and to provide you the most relevant content and experiences, we may combine information provided by you with information from third party sources, in accordance with applicable law. For example, the size, industry, and other information about the company you work for (where you have provided company name) will be obtained from sources including, professional networking sites and information service providers. 

Essafin software and website(s)

We collect information about how you use our software and website(s), including when you use a desktop software feature that takes you online. Depending on the software or website(s), this information may be anonymous or it may be associated with you. It includes:

• IP address;

• Type of browser and device;

• Webpage that led you to an Essafin website;

• Search terms entered into a search engine which lead you to an Essafin website;

• Use and navigation of website(s) and software (collected through cookies and similar technologies, or by Essafin servers when you are logged in to the software or website(s));

• Analysis of your content (e.g., documents, photos, videos, activity logs, and direct feedback from you) which is sent or received using an online feature of an Essafin software or website(s), or which is stored on Essafin servers.

Essafin emails

Emails we send you may include a technology (called a web beacon) that tells Essafin whether you have received or opened the email, or clicked a link in the email. If you do not want us to collect this information, you can opt out of receiving Essafin marketing emails.

Essafin online advertising

Essafin advertises online in a variety of ways, including displaying Essafin ads to you on other companies' website(s) and software and on social media platforms, such as LinkedIn. Essafin website(s) use cookies and similar technologies provided by our own company and other companies that allow us to gather additional information to measure and improve the effectiveness of our advertising. We collect information such as:

• Which ads are displayed;

• Which ads are clicked on; and 

• Where the ad was displayed. 

Buttons, tools, and content from other companies

Essafin software and website(s) may include buttons, tools, or content that link to other companies’ services. We may collect information about your use of these features. In addition, when you see or interact with these buttons, tools, or content, or view an Essafin web page or software containing them, some information from your browser may automatically be sent to the other company. Please read that company’s privacy policy for more information.

Essafin social networking pages and social sign-on services

You may eventually be able to sign into some Essafin software or website(s) using a social networking account, such as a Facebook account. Where you give appropriate permissions, we will receive information about you from your social networking account, such as name, location, basic demographic information.

Essafin has its own pages on many social networking sites. We will collect information which you have made publicly available on your social networking account, such as name and interests in our products and services, when you interact with our social networking pages. The social networking sites may provide statistics and insights to Essafin which help us understand the types of actions that people take on our pages. Where applicable, Essafin and the social media site(s) have entered into an arrangement which determines our respective responsibilities.

Essafin acting on your behalf

In certain instances, Essafin is acting only on your behalf for personal information collected and processed by our services (for example, for the address book contacts shared by users when entering recipient information). In such cases, Essafin is acting only on your instructions in order to facilitate the service requested by you, and you will be responsible for the information shared. When this occurs we will inform you through in-software notifications or other in-time communications.

How does Essafin use the information it collects about me, and what are the legal bases for these uses?

Essafin uses the information we collect about you for the following purposes:

• To fulfill a contract, or take steps linked to a contract: this is relevant where you register to use an Essafin software or website(s) (whether paid, or as a free trial).
  
  This includes:
  
  

  • Providing you with the Essafin website(s) and software for which you have registered, and any other services or products that you have requested;
    
    

  • Verifying your identity;
    
    

  • Taking payments;
    
    

  • Sending you necessary communications (for example, related to payments or expiration of your subscription); and
    
    

  • Providing customer service or support.
    
    

• As required by Essafin to conduct our business and pursue our legitimate interests, in particular:
  
  

  • Providing you with the Essafin website(s) and software for which you have registered and any other products and services you have requested;
    
    

  • Analyzing your use and measuring effectiveness of our website(s) and software to better understand how they are being used so we can improve them and engage and retain users;
    
    

  • Sending you information about Essafin products and services, special offers and similar information, and sharing your information with third parties for their own marketing purposes (where your consent is not required);
    
    

  • Analyzing your use of our website(s) and software, and interaction with our communications, to tailor and customize the website or software, and marketing communications
    
    

  • Using automated systems to analyze your content through techniques such as machine learning in order to improve our services and the user experience (where your consent is not required);
    
    

  • Diagnosing problems in our software and website(s);
    
    

  • Detecting, preventing, or otherwise addressing fraud, security or technical issues, as well as to protecting against harm to the rights, property or safety of Essafin, our users, or the public;
    
    

  • Conducting surveys and market research about our customers, their interests, the effectiveness of our marketing campaigns, and customer satisfaction (unless we need consent to undertake such surveys, in which case we will only do this with your permission);
    
    

  • Investigating and responding to any comments or complaints that you may send us;
    
    

  • Checking the validity of the sort code, account number and card number you submit if you use a credit or debit card for payment, in order to prevent fraud. 
    
    

  • Sharing account information registered under a business email address with employers for account migrations purposes;
    
    

  • If we merge with or are acquired by another company, sell an Essafin website, software, or business unit, or if all or a substantial portion of our assets are acquired by another company, your information will likely be disclosed to our advisers and any other prospective purchaser's advisers and will be one of the assets that is transferred to the new owner; and
    
    

  • In connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of information in connection with government agency requests, legal process or litigation).

Where we process your information based on legitimate interests, you can object to this processing in certain circumstances. In such cases, we will cease processing information unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons.

• Where you give Essafin your consent or otherwise consistent with your choices:
  
  

  • Sending you information about Essafin products and services, special offers and similar information, and sharing your information with third parties for their own marketing purposes (where your consent is required);
    
    

  • Placing cookies and using similar technologies on our website(s), on our software and in email communications, and the information provided to you when those technologies are used;
    
    

  • Accessing information stored on your device relating to your use of, and engagement with, website(s) and software and crash reports;
    
    

  • Accessing information stored on your device which you allow us to receive through device-based settings (e.g., photos, location and camera) in order to provide certain functionality within our software and website(s); and
    
    

  • Using automated systems to analyze your content using techniques such as machine learning in order to improve our services and the user experience (where your consent is required);

On other occasions where we ask you for consent, we will use the information for the purposes which we explain at that time. Where we rely on consent to process data, you can withdraw your consent to such activities at any time.

• For legal reasons:
  
  

  • Responding to requests by government or law enforcement authorities conducting an investigation.
    
    

  • To detect, prevent, or otherwise address fraud, security, potential illegal activities, or technical issues and software piracy (e.g., to confirm that software is genuine and properly licensed), helping to protect you, as well as Essafin.

Where this processing and these disclosures are not strictly required by law, Essafin may rely on its legitimate interests and those of third parties described above.

Does Essafin share my personal information?

Sharing with other Data Controllers

We will share your personal information within the corporate family of Essafin for the purposes identified above. We will also share your personal information with other third-party data controllers. The types of third parties your information may be shared with include, our resellers and other sales and advertising partners, retailers, research organizations, advertisers, ad agencies, advertising networks and platforms, information service providers, fraud monitoring and prevention providers, publishers, and non-profit organizations (with your consent, if required). Third-party data controllers may also use Essafin services to collect and process your personal information. If you are using an email address that is associated with a business domain (e.g.,yourname@businessname.com) to access Essafin's software and website(s), or if you were invited to use the software and website(s) by a business, we may provide your personal information to that business.

Sharing for Fraud Prevention Purposes

We will share personal information with companies, organizations or individuals outside of Essafin if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to detect, prevent, or otherwise address fraud, security or technical issues, as well as to protect against harm to the rights, property or safety of Essafin, our users, or the public as required or permitted by law.

Sharing with Data Processors

We will also share your personal information with companies that help us to run our business by processing personal information on behalf of Essafin for the purposes identified above. Such companies include providers of customer support services, payment processing services, fraud monitoring and prevention, email, social media, and other marketing platforms and service providers, and hosting services. We require these companies to protect your personal information consistent with this Privacy Policy.

Other Information Sharing

Essafin may also share your personal information:

• When you agree to the sharing;

• When we are required to provide information in response to a subpoena, court order, or other applicable law or legal process;

• When we have a good faith belief that the disclosure is necessary to prevent or respond to fraud, defend our software or website(s) against attacks, or protect the property and safety of Essafin, our customers and users, or the public;

• If we merge with or are acquired by another company, sell an Essafin website, software, or business unit, or if all or a substantial portion of our assets are acquired by another company, your information will likely be disclosed to our advisers and any prospective purchaser's advisers and will be one of the assets that is transferred to the new owner.

• We may share or publish aggregate information that doesn’t specifically identify you, such as statistical information about visitors to our website(s) or statistical information about how customers use Essafin. 

Is my personal information displayed anywhere on Essafin’s website(s) or applications or software?

There are several places within Essafin’s website(s) and software that allow you to post comments, upload pictures, or submit content for others to see. Sometimes you can limit who can see what you share, but there are some places where what you share can be seen by the general public or other users of the software or website(s). Please be careful when you share your personal information. Do not share anything you wouldn’t want publicly known unless you are sure you are posting it within a software or website(s) that allows you to control who sees what you post. Please note that when you post messages on certain user forums on our website(s) and software, your email address or name and/or profile photo may be included and displayed with your message.

To remove content you have shared on our website(s) and software, please use the same software or website(s) feature you used to share the content. If another user invites you to participate in shared viewing, editing, or commenting of content, you may be able to delete your contributions, but usually the user who invited you has full control.

Is my personal information secure?

We work hard to protect your personal information, and we take precautions to protect your information. We employ administrative, technical, and physical security controls where appropriate, such as encryption, 2-step verification, and strict contractual confidentiality obligations for employees and contractors.

When you submit sensitive information, your information is protected both online and offline. Wherever we collect sensitive information (such as credit card data), that information is encrypted and transmitted to us in a secure way. You can verify this by looking for a lock icon in the address bar and looking for "HTTPS" at the beginning of the address of the Web page. While we use encryption to protect sensitive information transmitted online, we also protect your information offline. Only employees who need the information to perform a specific job (for example, billing or customer service) are granted access to personally identifiable information. The place in which we store personally identifiable information is kept in a secure environment.

Where does Essafin store my personal information?

Your personal information and files are stored on Essafin’s servers and the servers of the companies we hire to provide services to us. These companies are primarily based in Canada. 

Does Essafin transfer my personal information across national borders?

We may transfer your personal information across national borders to other countries in compliance with applicable laws.

What rights do I have in respect of my personal information and how can I exercise these rights?

You have the right to ask us for a copy of your personal information; to correct, delete or restrict (stop any active) processing of your personal information; and to obtain the personal information you provide to us for a contract or with your consent in a structured, machine readable format, and to ask us to share (port) this information to another controller.

In addition, you can object to the processing of your personal information in some circumstances (such as where we are using the information for direct marketing).

These rights may be limited, for example, if fulfilling your request would reveal personal information about another person, or if you ask us to delete information which we are required to keep or which we need to defend claims against us.

To exercise any of these rights (including deactivating your Essafin ID account), you can get in touch with us using the details set out below.

Additionally, our website(s) and software allows you to edit your personal information by accessing the “my account” or “my profile”, or a similar feature of the software or website(s) you are using. Likewise, you can delete additional information that you have stored in our website(s) and software by logging in and using the deletion functions that are available.

If you have unresolved concerns, please reach out to us directly.

To register with Essafin, to create an Essafin ID, and to use some Essafin website(s), software, products or services, the provision of some information is mandatory: if relevant information is not provided, then we will not be able to administer an Essafin account to you, or provide you with the website(s), software, products or services requested. All other provision of your information is optional. Providing optional information will help us offer you a better experience, such as more personalized or tailored content or offerings.

Withdrawing consent or otherwise objecting to direct marketing.

Other companies we hire to help market our website(s) and software on our behalf may use your information to provide you with information and offers related to Essafin. 

Where we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your information for other purposes, such as those set out above. In some cases, we are able to send you direct marketing without your consent, where we rely on our legitimate interests. You have an absolute right to opt-out of direct marketing, or profiling we carry out for direct marketing, at any time by:

• updating your preferences in your Essafin ID profile;

• updating your preferences in your specific website or software accounts;

• clicking the unsubscribe link at the bottom of our marketing emails; or

• contacting us directly

How long does Essafin retain my information?

When you register for an Essafin ID account, we process and keep most personal information we have about you for as long as you are an active user of our products or services. When you close your account, we begin deleting certain personal information that we no longer have a business reason to retain, such as your protected password and your protected payment account data. However, we typically retain personal information related to our contract and business transactions with you for seven years after your last interaction with us.

Where we process personal information for marketing purposes or with your consent, we process the information until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a permanent record of the fact that you have asked us not to send you direct marketing or to process your information so that we can respect your request in future.

Will this privacy policy change?

Occasionally, we may change this privacy policy to allow Essafin to accommodate new technologies, industry practices, regulatory requirements or for other purposes. If we do, we will change the "last updated" date at the top of this policy and the revised policy will be posted to this page so that you are aware of the information we collect, how we use it, and under what circumstances we may disclose it. Under certain circumstances (for example with certain material changes) we will provide notice to you of these changes and, where required by applicable law, we will obtain your consent. Notice may be by email to you, by posting a notice of such changes on our software and website(s), or by other means consistent with applicable law. 

Who can I contact with questions or concerns?

If you have a privacy question, concern, or request, please fill out our contact form on our website - www.essafinlogic.com