At CLOBE CONNECT INC, we are committed to protecting your privacy and safeguarding your personal, business and financial information. This Privacy Statement applies to CLOBE CONNECT INC and its respective affiliates in Canada (collectively, “Clobe Connect”, “we” or “our”).
The purpose of this Privacy Statement is to inform you about the types of Personal Information, as defined below, that Clobe Connect collects, uses, and discloses. It explains how we use and disclose that information, the choices you have regarding such use and disclosure, and how you may correct that information.
This Privacy Statement is designed to meet the standards prescribed by the Personal Information Protection and Electronic Documents Act and the regulations thereunder (“PIPEDA”) as well as applicable provincial privacy legislation and regulations, including but not limited to, the Personal Information Protection Act (British Columbia), the Personal Information Protection Act (Alberta), the Personal Health Information Protection Act (Ontario) and An Act respecting the protection of personal information in the private sector (Quebec). We also note that in addition to these laws, we continue to be subject to the confidentiality rules of the Institutes of Chartered Professional Accountants.
Personal Information is any information that is identifiable with you, as an individual. This information may include, but is not limited, to your mailing address, telephone number, email address, Internet Protocol (“IP”) address, age, gender, marital status, health information, financial status, credit card information and credit history. Personal Information, however, does not include your business title, business address or business telephone number in your capacity as an employee of an organization.
We will always collect your Personal Information by fair and lawful means (for example, when you engage us to provide services, use the Clobe Connect website, become a member of Clobe Platform or speak to a Clobe Connect representative). We collect Personal Information directly from you, or indirectly from third party sources as otherwise permitted by applicable law.
By providing your personal information, you consent to Clobe Connect using that information in the ways described in this Privacy Statement or as described at the point where you choose to disclose this information. With respect to our websites, Clobe Connect may use cookies, log files and web beacons to collect information regarding the use of the websites. Generally, this information is non-identifiable and would likely not be considered Personal Information.
Cookies: Cookies are small text files placed on your hard drive that assist us in providing a more customized website experience. For example, a cookie can be used to store registration information in an area of the site so that a user does not need to re-enter it on subsequent visits to that area. It is Clobe Connect’s policy to use cookies to make navigation of our websites easier for visitors and to facilitate efficient registration procedures. If you are concerned about cookies, most browsers permit individuals to decline cookies. In most cases, a visitor may refuse a cookie and still fully navigate our Web sites.
Log files: In order to properly manage our website, we may anonymously log information on our operational systems, and identify categories of visitors by items such as domains and browser types. These statistics are reported in the aggregate to our webmasters and are generally non-identifiable.
Web beacons: To gather visitor statistics and manage cookies, we use electronic images called a “single-pixel GIF” or “web beacon.” Web beacons allow our third-party tracking tools, Adobe Analytics, Google Analytics and Oracle Marketing Cloud to gather information such as the IP address of your computer, the time the material was viewed, and the type of Internet browser used to access the page. This information is tracked on the third-party tracking tools’ servers and reported in aggregate to our webmasters. If you are concerned about the use of Web beacons you can turn off your browsers’ cookies. This action will prevent Web beacons from tracking your specific activity; however, the Web beacon may still record a visit from your IP address.
Finally, Clobe Connect understands the importance of protecting children’s privacy online. The Clobe Connect websites covered by this Privacy Statement are not intentionally designed for or directed at children 13 years of age or younger. It is Clobe Connect’s policy never to knowingly collect or maintain information about anyone under the age of 13.
Personal Information that is “in the cloud” may be stored on multiple servers in a number of locations around the world. Rest assured that Clobe Connect has taken appropriate steps for the protection of Personal Information handled by our service providers. However, information transmitted to other countries may be subject to the laws and lawful disclosure requirements of the jurisdiction(s) where the information is stored.
We generally use your Personal Information for the following purposes (the “Purposes”):
We identify to whom, and for what purposes, we disclose your Personal Information, at the time we collect such information from you and obtain your consent to such disclosure.
For example, we may transfer your Personal Information to third party service providers with whom we have a contractual agreement that includes appropriate privacy standards, where such third parties are assisting us with the Purposes — such as service providers that provide telephone support or data storage or processing.
Generally, we will only make disclosures of Personal Information to such persons for which you provide your consent. Notwithstanding the foregoing, we may also make disclosures of Personal Information to a potential acquirer in connection with a transaction involving the sale of some or all of the business of Clobe Connect or as otherwise permitted or required by law, in which case the use of your Personal Information by the new entity would continue to be limited by applicable law.
In addition, we may send Personal Information outside of the country for the purposes set out above, including for process and storage by service providers in connection with such purposes. To the extent that any Personal Information is out of the country, it is subject to the laws of the country in which it is held, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country.
With respect to the Clobe Connect websites, this Privacy Statement applies to the websites located within www.clobeconnect.com/.
We generally obtain your consent prior to collecting, and in any case, prior to using or disclosing your Personal Information for any purpose. You may provide your express consent to us either orally, electronically or in writing. You may also consent to Clobe Connect’s collection, use and disclosure of Personal Information by voluntarily providing us with Personal Information through a clear, affirmative action (e.g. by submitting an information request, participating in a survey, etc.). Clobe Connect may also rely on your implied consent to the collection, use and disclosure of your Personal Information where implied consent is permitted under applicable law.
We ensure that all affiliates and other third parties, including Clobe Connect member firms, which are retained to perform services on our behalf and are therefore provided with Personal Information are contractually required to observe the intent of this Privacy Statement.
We may keep a record of your Personal Information, correspondence or comments in a file specific to you. We will use, disclose or retain your Personal Information for as long as necessary to fulfill the purposes for which that Personal Information was collected, or as permitted or required by law.
We will ensure that your Personal Information is kept as accurate, complete and up-to-date as possible. We will not routinely update your Personal Information, unless such a process is necessary. We expect you, from time to time, to supply us with written updates to your Personal Information, when required. At any time, you can challenge the accuracy or completeness of your Personal Information in our records. If you successfully demonstrate that your Personal Information in our records is inaccurate or incomplete, we will amend the Personal Information as required. Where appropriate, we will transmit the amended information to third parties having access to your Personal Information.
We may request that you provide sufficient identification to permit access to the existence, use or disclosure of your Personal Information. Any such identifying information shall be used only for this purpose.
All comments, questions, concerns or complaints regarding your Personal Information or our Privacy Statement, should be forwarded to us through email as given on Contact us page.