Personal Information Protection Policy

Privacy Policy

We are committed to safeguarding the Personal Information entrusted to us by our clients. We manage your Personal Information in accordance with applicable privacy laws.

This Privacy Policy forms part of our Terms of Service at https://grype.ca/terms-of-service, which we encourage you to review. Any terms used but not defined in this Privacy Policy have the meaning given to them in the Terms of Service.

Our Services are not intended for use by minors, or anyone under the age of 13. If you do not meet applicable age requirements, please do not use our Services.

What is Personal Information?

Personal Information means information about an identifiable individual. For example, Personal Information includes an individual’s name, home address and phone number, age or gender.

What Personal Information do we collect?

We collect only the Personal Information that we need for the purposes of providing services to our clients, including your:

Name;

IP Address;

Home Address;

Telephone Number;

Email Address;

User Information;

Any other information you provide to us, so that we can provide you with the Service.

Why We Collect, Use and Disclose Personal Information

We collect, use, and disclose Personal Information to provide Service to you.  Our reasons for collection include:

  • providing the Service;
  • developing and manage digital solutions, such as email campaigns, websites, etc.;
  • following up with clients to determine client satisfaction;
  • providing strategic insight into digital-marketing options;
  • notifying clients of upcoming events of interest;
  • internal business processes and automation; and
  • meeting regulatory requirements

Consent

We ask for your express consent for some purposes (such as providing your Personal Information to a third party or Sub-Processor) and may not be able to provide certain services if you are unwilling to provide consent to the collection, use, or disclosure of certain Personal Information. Where express consent is needed, we may ask you to provide consent orally or in writing, or by email.

Other times, you may provide your implied consent to our collection, use or disclosure of Personal Information when we can reasonably conclude that you have given consent by some action you have taken or an action you have decided not to take.  Generally, this occurs where the purpose for the use of your Personal Information would be reasonably apparent to you – for example, when you provide us with your name on your Account, you provide us with implied consent to use your name to facilitate your provision of Services.

You may withdraw consent to the use and disclosure of Personal Information at any time, unless the Personal Information is necessary for us to fulfil our legal obligations. We will respect your decision, but we may not be able to provide you with certain products and services if we do not have the necessary Personal Information. To withdraw your consent, you may contact us at support@grype.ca.

How do we use and disclose Personal Information?

We use and disclose Personal Information only for the purposes for which the information was collected, except as authorized by law. If we wish to use or disclose your Personal Information for any new- business purpose, we will first ask for your consent.

Your Personal Information and Sub-Processors

We use Sub-Processors to facilitate payment, host our website and for internal business management. Some of our Sub-Processors may be located outside of your jurisdiction. Where that is the case, we incorporate the appropriate safeguards to protect your Personal Information. We ensure that our Sub-Processors maintain substantially equivalent privacy protections and practices. Where Sub-Processors are used, their terms of service and privacy policies apply.

Our Sub-Processor List can be found here.

How do we safeguard Personal Information?

We make reasonable efforts to maintain up-to-date Personal Information by enabling Users and Customers to update their Personal Information through their Account.  If you are aware of an error in our information about you, please let us know and we will correct it on request wherever possible.

We protect your Personal Information in a manner appropriate for the sensitivity of the information, including the use of organizational, technical and physical safeguards. We make every reasonable effort to prevent any loss, misuse, disclosure or modification of Personal Information, as well as any unauthorized access to Personal Information. Sensitive information is accessible on a need-to-know basis only.

We will notify the Office of the Privacy Commissioner of Canada, without delay, of a security breach affecting Personal Information if it creates a real risk of significant harm to individuals.

We render client Personal Information de-identify or destroy records containing Personal Information once the information is no longer needed.

Access to Records Containing Personal Information

You have a right of access to your Personal Information in a record that is in our custody or under our control, subject to some exceptions (for example, where access to your Personal Information would reveal Personal Information about another individual, or confidential business information.) You may also request information about our use of your Personal Information and any disclosure to our Sub-Processors. To access or request to have your Personal Information deleted, please contact Farhad Khan at farhad@grype.ca and we will do so within 30 days. 

If we refuse a request in whole or in part, we will provide the reasons for the refusal. In some cases where exceptions to access apply, we may withhold that information and provide you with the remainder of the record.

We may charge you a reasonable fee to provide information, but not to make a correction. We will advise you of any fees that may apply before beginning to process your request. Some jurisdictions prohibit us from collecting any fees to provide your Personal Information. If you are a resident of any such jurisdiction, this section does not apply to you.

Québec Residents

If you are a resident of Québec, you may have additional rights under Québec’s Law 25, An Act to Modernize Legislative Provisions as Regards the Protection of Personal Information, which come into force on a rolling basis between September 2022 and September 2024. As this law comes into force, we will continue to revise our Privacy Policy to keep you updated on how you can exercise your rights.

California Consumer Privacy Act (“CCPA) & California Privacy Rights Act (“CPRA”)

In addition to the rights set out above, if you are a resident of the State of California, you have the following additional rights:

  • Right to Access: You have the right to access your Personal information by emailing us at support@grype.ca or 613-518-6070. We will provide you with your Personal Information within 45 days, after verifying your identity, at no charge to you. If we are unable to fulfill your access request, we will notify you of the reason and provide you information regarding appealing our decision.
  • Right to Data Portability: we will select a commercially reasonable format to provide your Personal Information that is commonly useable and should allow you to transmit the information from one entity to another entity without hindrance, but we do not guarantee that all formats are useable in all media.
  • Right to Limit Use and Disclosure of Sensitive Personal Information: In our effort to enhance diversity, inclusion and equity, we may collect Sensitive Personal Information, such as information about your ethnic or racial origin. We exclusively use this information as it pertains to providing discounts to Customers representing visible minorities. We do not otherwise access or use this information in any way that makes inferences about you.
  • Right to Opt-Out of Sale: We do not sell your Personal Information.
  • Right to Opt-Out of Automated Decision Making: We may implement behavioural advertising, which requires some automated decision making about you. You have the right to opt-out of such profiling by emailing us in accordance with this Privacy Policy.

Categories of Personal Information 

Personal Information we collect in this category (See the “What Personal Information do we collect?” section above for description)

Identifiers (excluding online identifiers)

  • Name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers

California Customer Records (as defined in California Civil Code section 1798.80)

  • Name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit or debit card number, other financial information, medical information, health insurance information

Characteristics of protected classifications under California or federal law

  • Race, religion, sexual orientation, gender identity, gender expression, age

Commercial Information

  • Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies

Biometric information

  • Hair color, eye color, fingerprints, height, retina scans, facial recognition, voice, and other biometric data

Internet or other electronic network activity information

  • Browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement

Geolocation Information

  • Information about your precise location based on your device’s GPS location

Sensory Information

  • Information we capture through security cameras at our offices and facilities

Professional or employment related information

  • Job history
  • Performance evaluations

Non-public education information

  • Grades
  • Transcripts
  • Class Schedules
  • Disciplinary records

Inferences

May be derived from the information listed above

 

Sources. We describe the sources from which we collect this Personal Information in the section above entitled “What Personal Information do we collect?” 

Purposes. We describe the business and commercial purposes for which we collect this Personal Information in the section above entitled “Why We Collect, Use and Disclose Personal Information”

Disclosure. We disclosed this Personal Information to the categories of third parties described in the section above entitled “How do we use and disclose Personal Information?”.

 

Questions and Complaints

If you have a question or concern about any collection, use, or disclosure of Personal Information by Grype Solutions or about a request for access to your own Personal Information, please contact Farhad Khan:

Farhad Khan

CEO, Grype Solutions

support@grype.ca

613-518-6070

2821 Riverside Drive

Ottawa, Ontario

K1V 8N4

If you are not satisfied with the response you receive, you may contact the Office of the Privacy Commissioner of Canada:

            Office of the Privacy Commissioner of Canada

            819-994-5444

            30, Victoria Street

            Gatineau, Québec 

            K1A 1H3

For more information, please visit https://www.priv.gc.ca/en

This Privacy Policy was last updated on November 11, 2022.