What this policy covers
Our Application collects personal data from the individual using the Services who, unless otherwise specified, coincides with the Data Subject (hereinafter the “User”) including:
Personal Data (or Data): Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Usage Data: Information collected automatically, which can include: the IP addresses or domain names of the computers utilized by the users who use Divii Services, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the user, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.
Types of Data collected
The Website and Application collect personally identifiable information such as names and addresses (e-mail and physical) only from visitors who voluntarily input such information through various mechanisms, including contact forms and subscription sign ups. We also collect email addresses from the emails you send us directly. We will use personally identifiable information in cases where the User has opted in to receiving email marketing from Us, or to update the User regarding changes to their account or the Services. The data we hold is kept securely and only accessed by authorized personnel.
Any Personal Data is collected for the following exclusive purposes:
Displaying content from external platforms
Complying with legal obligations
In cases where the Website or Application specifically state that some Data is not mandatory, Users are free not to communicate this data without consequences to the availability or the functioning of the services provided by this Application as described on this Website and Application (the “Services”). Users who are uncertain about which personal data is mandatory are welcome to contact client care here: firstname.lastname@example.org.
Methods of processing
Computers used to access our Services automatically transmit certain non-personally identifiable information when you visit our sites, such as the type of browser you are using or the domain name of your Internet service provider. They also collect aggregate information on the site pages our users visit. Our ability to limit collection of this data is limited, as it cannot control, for example, whether an individual user’s non-personally identifiable information is gathered by Google Analytics or a similar service. Thus, the user is responsible for the user’s own settings on any computer used to access our Services, and the user is thus responsible for determining whether information is transmitted from its device to Us through any means. Computer data containing no personally identifiable information will be used only for internal business purposes.
Congruo Solutions Inc. takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In some cases, the data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as data processors.
Legal basis of processing
We may process personal data relating to users if one of the following applies:
users have given their consent for one or more specific purposes;
provision of data is necessary for the performance of a service;
processing is necessary for compliance with a legal obligation to which we subject; or
processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in Congruo Solutions Inc.
The data is processed at our operating offices and in any other places where the parties involved in the processing are located.
Our information is exclusively held in servers located in Canada.
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
Personal data collected for purposes related to the performance of a contract between Us and the User shall be retained until such contract has been fully performed. After the services have been rendered, We will have 6 months to delete all the identifiable personal data of the user.
In case there is no express agreement, data will be stored for a maximum of 1 year.
Congruo Solutions Inc. may be allowed to retain personal data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, Divii may be obliged to retain personal data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, personal data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The rights of Users
Users may exercise certain rights regarding the Data we collect and process.
In particular, Users have the right to do the following:
Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
Access their Data. Users have the right to learn if Data is being processed by Congruo Solutions Inc., obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, we will not process their Data for any purpose other than storing it.
Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from our systems.
Unless required by law to do so, we will not sell, share, or otherwise disclose any of the information it collects online without your permission except for internal business purposes.
How to exercise these rights
Any requests to exercise User rights can be directed to Congruo Solutions Inc. through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by our team as early as possible and always within one month.
The services are intended for the use of Canadian residents. If you access the websites from outside Canada, Congruo Solutions Inc. explicitly disclaims liability for compliance with the user’s local laws related to data collection and online privacy. For a Non-Canadian User who proceeds to use the Website and/or Application despite this warning, only this policy shall apply.
This Application uses Trackers. A cookie is a piece of data stored on a user’s device containing information about the user’s visit. Cookies are of various types and have different purposes but they mainly allow us to track and target the interests of our users. You can disable or remove any cookies already stored on your device, but these may stop our Application from functioning properly. You can find out how to do this, and find more information on cookies, at: www.allaboutcookies.org Law Firms and Lawyers that work with consumers enter into attorney-client relationships with its clients pursuant to certain policies and procedures unrelated to this site. To the extent we possess information protected by the attorney-client privilege, Congruo Solutions Inc. will take all reasonable steps to ensure the ongoing confidentiality and privilege of such information.
Categories of personal information collected, disclosed or sold
In this section we summarize the categories of personal information that we’ve collected, disclosed or sold and the purposes thereof.
Information we collect: the categories of personal information we collect
We have collected the following categories of personal information about you: internet information, personal data such as name, email address and other identifiable personal data, and usage data.
We will not collect additional categories of personal information without notifying you.
How we collect information: what are the sources of the personal information we collect?
We collect the above mentioned categories of personal information, either directly or indirectly, from you when you visit our site.
For example, you directly provide your personal information when you submit requests via any forms to us. You also provide usage information indirectly when you navigate the site, as that information is automatically observed and collected. Finally, we may collect your personal information from third parties that work with us in connection with the Service or with the functioning of this Application and features thereof.
How we use the information we collect: sharing and disclosing of your personal information with third parties for a business purpose
We may disclose the personal information we collect about you to a third party for business purposes. In this case, we enter a written agreement with such a third party that requires the recipient to both keep the personal information confidential and not use it for any purpose(s) other than those necessary for the performance of the agreement.
We may also disclose your personal information to third parties when you explicitly ask or authorize us to do so, in order to provide you with our Service.
Sale of your personal information
For our purposes, the word “sale” means any “selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating orally, in writing, or by electronic means, a consumer’s personal information by the business to another business or a third party, for monetary or other valuable consideration”.
This means that, for example, a sale can happen whenever an application runs ads, or makes statistical analyses on the traffic or views, or simply because it uses tools such as social network plugins and the like.
We do not sell directly or indirectly your personal information.
What are the purposes for which we use your personal information?
We may use your personal information to allow the operational functioning of this Application and features thereof (“business purposes”). In such cases, your personal information will be processed in a fashion necessary and proportionate to the business purpose for which it was collected, and strictly within the limits of compatible operational purposes.
We may also use your personal information for complying with the law and defending our rights before the competent authorities where our rights and interests are threatened or we suffer an actual damage.
We will not use your personal information for different, unrelated, or incompatible purposes without notifying you.