- what information is gathered by NeverCryWolf Inc. (“us“, “our” and “we“) from those who visit and use the Site (individually, “you” or collectively, “Users“);
- how and why we use your information;
- to whom your information may be disclosed;
- how we protect your information;
- updating, accessing, deleting and retaining your information, and
- providing or withdrawing your consent to our collection, use or disclosure of your information.
1. What Information We Collect
- Your relationship with us. We will collect information arising from your relationship with and through us and your use of the Site. For example, when you send us an e-mail, speak with one of our telephone service representatives, or communicate with us through any other means, we may monitor, record and retain those communications for our mutual protection and in order to process your inquiries, respond to your requests and improve our services.
2. How and Why Your Personal Information is Used.
- To Serve you. We use the information that you provide or that we collect in order to provide our products and services to you and to establish and enhance our relationship with you. We generally use the information you provide or that we collect to operate, maintain, enhance, and provide our products and services, including providing you with access to only those sections of the Site that are associated with your account.
- Aggregate Information. We may generate non-identifying and aggregate profiles from the information you provide during registration for our products and services and through your use of our products and services. Non- identifying and aggregate profiles are used to improve the quality of our products and services and to develop new services and products.
- Marketing and Experience. If you have given us consent, we may use your Personally Identifiable Information to provide you with information about our features, services and other offerings that may be of interest to you.
3. To Whom your Personal Information may be disclosed.
- Our subsidiaries or affiliates. We may share your Personal Information with our subsidiaries or affiliates (the “Group”) for legal and regulatory purposes, to manage business risks, to perform analytics, to ensure that we have correct and up to date information about you and to the extent necessary if you have requested a product or service that is jointly offered by more than one member of the Group.
- Suppliers. We may use other companies to provide services on our behalf. These companies will only be given the information needed to perform those services. We have contracts in place holding these companies to the same standards of confidentiality by which we are governed. Our suppliers may perform activities outside of Canada. As a result, your information may be securely used, stored or accessed in other countries and may be subject to the laws of those countries. These companies may be required to disclose your Personal Information in response to valid demands or requests from governments, regulators, courts and law enforcement authorities in those jurisdictions or countries.
- Merger or sale. In the event that we are acquired by or merged with a third- party entity, or if we sell a part of the our business, we reserve the right to transfer or assign the Personal Information that we have collected from you as part of such merger, sale or other change of control.
- Where required by law. We may disclose your Personal Information if we have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to satisfy any applicable law, regulation, self-regulation, legal process or enforceable governmental request. When we provide information in response to a legal inquiry or order that we believe to be valid, we disclose only the information that is legally required. Note that we may process your Personal Information on our servers in Ontario, Canada and in other countries as may be necessary. In such cases your Personal Information may be disclosed in response to valid demands or requests from governments, regulators, courts or law enforcement authorities in those jurisdictions or countries.
- Protection of our interests. We may also disclose your Personal Information if we believe, in good faith, that it is appropriate or necessary to take precautions against liability; to help us collect a debt or enforce an obligation owed to us by you; to protect against fraudulent, abusive, or unlawful uses; to investigate and defend ourselves against any third-party claims or allegations; to assist government enforcement agencies; to protect the security or integrity of our products and services; or to protect the rights, property, or personal safety of our Users, employees or others.
- Consent. We may disclose your Personal Information where you have authorized us to do so. For example, if you have given us consent, we may share your Personally Identifiable Information with business partners and other entities that are not affiliated with us who would like to send you information about their products and services. We do not share Personally Identifiable Information with other third-party organizations for their marketing or promotional use without your consent or except as part of a specific program or feature for which you will have the ability to opt-in.
4. How we protect your Personal Information.
- Security processes. We make commercially reasonable efforts to safeguard your Personal Information from loss or theft, unauthorized access, disclosure, duplication, use or modification through security measures appropriate to the sensitivity of the information. These measures include internal reviews of our data collection, storage and processing practices and security measures which include appropriate encryption and physical security measures to guard against unauthorized access to systems where we store Personal Information.
5. Updating, Accessing and deleting your Personal Information.
- Updating, Accessing and deleting your Personal Information. We make good faith efforts to provide you with access to your Personally Identifiable Information and to delete such data at your request if it is not otherwise required to be retained by law or for legitimate business purposes. We ask individual Users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup tapes), or for which access is not otherwise required. In any case where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort. We will advise you of any applicable fee prior to proceeding with your request.
- Retention of your Personal Information. We retain your Personal Information only as long as it is required for the reason(s) that it was collected. This length of time will vary depending on the product or service and the nature of the information and may extend beyond the end of your relationship with us. When your information is no longer needed for the purpose for which it was collected, we will destroy, delete, erase or convert it to an anonymous form.
6. Providing or withdrawing your consent.
- We will obtain your consent before collecting, using or disclosing your Personal Information, except where permitted or required by law. Depending on the situation and the sensitivity of the information, we may obtain your consent in different ways. Express consent may be obtained verbally, electronically or in writing from you or your authorized representative (such as a legal guardian or attorney appointed pursuant to a power of attorney). Implied consent may be obtained through your use or continued use of a product or service, or when you approach us to obtain information, inquire about or purchase products or services from us.
- You may withdraw your consent provided that: you provide reasonable notice; we are not legally required to collect, use or disclose your information; and withdrawing your consent does not impede our ability to fulfill our obligations to you. You may withdraw your consent by contacting us at [enter company e-mail address] or by calling us at [enter company phone number]. Our staff will be pleased to explain your options and any consequences of refusing or withdrawing your consent, and record your choices.
- Several of the privacy preferences available to you, subject to legal, business or contractual requirements, are outlined below.
- Direct marketing. The Site may provide an option for you to consent to receive information that may be of interest to you through various channels including direct mail, telephone, electronic or other means. You may opt out of receiving such communications from us at any time by clicking on the “unsubscribe” link in any such electronic messages or by contacting us. Any marketing campaigns that are already underway may not immediately take your preferences into account.
- Sharing with our subsidiaries or affiliates. We may share your Personal Information with our subsidiaries or affiliates (the “Group”) for: fraud or crime prevention, suppression or detection; to meet regulatory, legal or reporting requirements; to manage business risks; to perform analytics; to ensure that we have correct and up to date information about you; and to the extent necessary if you have requested a product or service that is jointly offered by more than one member of the Group. You may not withdraw consent for this sharing. We may also share your information to better manage your total relationship with the Group and enable other members of the Group to bring suitable products and services to your attention. We may share your information within the Group for these purposes unless prohibited by law or you tell us not to.
- Suppliers. We may share Personal Information with our suppliers, agents and other organizations that perform services for us or on our behalf to the extent necessary to provide and administer the products and services that you have requested from us. If you withdraw your consent for this sharing, we may not be able to provide you with your requested product or service.
8. Third-Party Sites.
9. International Users.
If you are a User outside of Canada, please note that we process your Personal Information on our servers in Toronto, Ontario, Canada and in other countries as may be necessary. In some cases, we process your Personal Information outside your own country. Therefore, Canadian federal and provincial governments, courts, or law enforcement or regulatory agencies may be able to obtain disclosure of your information through laws applicable in Canada. Your use of the Site or your submission of any Personally Identifiable Information to us will constitute your consent to the transfer of your Personal Information outside of your home country, which may provide for different data protection rules then in your own country.
10. Complaints and Questions.
Last Revised: July 14, 2017