Privacy Policy

Computer Workware Inc.

(the “Company”, “we”, “us” or “our”)

PIPEDA

All organizations engaged in “commercial activities” must comply with the Personal Information Protection & Electronic Documents Act (Canada) (“PIPEDA”). PIPEDA requires organizations to comply with a series of rules based on principles. PIPEDA gives you rights.

What Information does this Privacy Policy apply to?

As required by PIPEDA, this Privacy Policy applies to Personal Information that is collected, used, or disclosed by us in the course of commercial activities.

Specifically, “Personal Information” is information, in any form, that could identify you as an individual through the use of that Personal Information alone or in combination with other available Personal Information. It can include, among other things, your characteristics, activities, opinions, evaluations and views, age, income, family status, education, medical and health history and conditions, goods or services purchased or received, criminal history, employment history, financial information and any identifying number, mailing address, e-mail address, phone number, credit card information and billing or service records.

This Privacy Policy applies to protect our customers, users of our products and services, and our employees, independent contractors, and agents.

However, if our independent contractors and agents (including advertisers and suppliers) ask you for Personal Information, and they are not asking on our behalf, and you provide Personal Information (a) we cannot be held liable for the collection, use, and disclosure of your Personal Information by such independent contractors and agents, (b) we cannot assume responsibility for their privacy practices or policies and their actions or inactions and (c) you should review the privacy policies of such parties before providing them with any Personal Information.

There are some exceptions in PIPEDA and at law as to what might otherwise ordinarily be considered Personal Information or commercial activity. The collection, use, and disclosure of Personal Information for employment purposes is not considered a “commercial activity”, and PIPEDA does not apply to it. When certain Personal Information, such as your name, address, telephone number, and e-mail address, is listed in a public directory, it is not protected by PIPEDA. Your business contact information such as name, title, business address, telephone number, and business e-mail address used in relation to your employment or business is also exempt. Information about you, but which could not identify you as an individual (such as de-identified information) is not Personal Information.

This Privacy Policy in a Snapshot

This Privacy Policy explains (a) how and why we collect, use and disclose your Personal Information, (b) how and when your consent will be requested and to exceptions to this, (c) how you can access your Personal Information and (d) whom to contact if you have questions or concerns about the privacy of your Personal Information.

Is this the Only Privacy Poilcy?

This Privacy Policy cannot address every situation where we deal with Personal Information. Some of our products or services (such as mobile applications because they are unique) may have specific privacy policies. These specific privacy policies form part of this Privacy Policy. Also, we may provide you with additional information about our privacy practices, including through our websites, our websites’ terms of use, online, app-based or e-mail notices or prompts, frequently asked questions, and other documents or methods. Personal Information of our employees may also be governed by other policies, codes of conduct, and employment agreements.

Can this Privacy Policy Change?

We may change this Privacy Policy (and other product or service-specific privacy policy) from time to time provided the Privacy Policy (or other product or service-specific privacy policy) continues to comply with PIPEDA and law. We will notify you of changes by (a) posting the change on our websites, mobile applications or social media accounts, (b) notice in your bill, (c) sending you an e-mail, text, or other message or (d) any other reasonable means.

Our Accountability to You

We recognize the importance of privacy of Personal Information. We are committed to responsibly and lawfully collecting, using, disclosing, protecting, retaining, and disposing of any Personal Information we receive in accordance with PIPEDA and at law.

We have or will, from time to time, undertake measures to ensure compliance with our Privacy Policy and that Personal Information is protected. Systems have or will be set up to receive and respond to complaints and inquiries. We will train our employees and officials regarding this Privacy Policy.

Why We Collect, Use and Disclose Your Personal Information

We use your Personal Information to provide you with our products and services. We may also use your Personal Information to (a) establish and maintain commercial relations with you and to provide ongoing products or services, (b) try to understand the needs and preferences of you and determine your eligibility for products and services, (c) recommend products and services to meet your needs, (d) develop, enhance, market or provide products and services, (e) manage and build business operations or (f) meet our legal and regulatory requirements.

If we identify a new purpose for the use of Personal Information, we will obtain your consent (if required by PIPEDA and law) to use that Personal Information for the new purpose before we so use that Personal Information.

Your Consent

Whether or not we need your consent and how we obtain your consent to the collection, use, and disclosure of your Personal Information, depends on the type of Personal Information and the particular circumstances.

Consent Not Needed

We do not need your consent to use your Personal Information if we are first “de-identify” or “anonymize” your Personal Information so that you cannot be identified as an individual. For example, we may use that de-identified or anonymized information to improve our operations, provide social benefits, and to develop analytic marketing reports for our internal and external use.

Sometimes it may be impossible or inappropriate to obtain your consent. In those cases, we may collect, use or disclose your information without your consent such as (a) it is clearly in your interests and consent cannot be obtained in a timely way such as a medical emergency or a threat to your safety, (b) to comply with a warrant or other court order, (c) to collect a debt, (d) to investigate the breach of an agreement or applicable law, (e) it was produced by you in the course of your employment, business or profession and our collection, use and disclosure is consistent with the purposes for which that Personal Information was produced and (f) as otherwise legally required or allowed under PIPEDA and at law.

Implied Consent

When it is reasonable in the circumstances or the Personal Information is not sensitive, we are permitted to and will imply consent from your actions. For example, if you give us your mailing or e-mail address, we may use it to send you newsletters, updates, marketing and promotions, bills, or other notices related to our products and services on the basis that your consent can be reasonably implied. Or, for example, when you sign up as a user with us or a customer of us, we rely on implied consent to track your service usage for the purpose of billing you (as applicable).

Express Consent

In other situations, we may need your express consent. For example, we would request your express consent before using your Personal Information to perform a credit check or, for example, we would request your express consent before using your Personal Information to enable individual location-based marketing for a third-party. “Express consent” is when you explicitly consent verbally, by signing a document, clicking or “ticking” a button or box or performing a similar act demonstrating your consent, whether by phone, e-mail, text, on our websites, mobile applications, social media accounts or the like.

When and How Do We Collect Your Personal Information?

It depends on why we are collecting it and the product or service it relates to. For example, we may collect your Personal Information (a) when you provide Personal Information during the inquiry, sign-up, activation or purchase process for a product or service or our websites, mobile applications or social media accounts or if you add Personal Information to our mailing or other lists, (b) when we provide a product or service including technical support or during a warranty or repair claim or service process (if applicable), (c) automatically when you use our products or services or visit one of our websites (such as through the use of cookies or similar technologies), (d) call into a call centre or message with an online help provider, (e) via security cameras when you shop in one of our retail or other locations (if any) or (f) from third-parties such as credit reporting agencies or other third-parties with whom you have had a payment relationship. By providing us with such Personal Information, you automatically consent to our collection, use, and disclosure of that Personal Information as further described in this Privacy Policy. Regarding our websites, mobile applications, and social media accounts, we monitor traffic patterns, usage, and related information in order to optimize our products and services.

Disclosure of Your Personal Information

We may disclose your Personal Information:

For any disclosure of your Personal Information other than described above, if your implied consent or express consent (as applicable) is required, we will request and need to obtain your implied consent or express consent (as applicable) before so disclosing your Personal Information.

Limiting the Collection of Your Personal Information

Our collection of Personal Information will be limited to that which is necessary to fulfill the purposes which were identified. Our collection of Personal Information will also be by fair and lawful means.

Limiting the Use, Disclosure, and Retention of Your Personal Information

We may not use or disclose Personal Information for purposes other than for which it was collected except with your consent (implied or express, as applicable) or where your consent is not required, in certain circumstances listed in PIPEDA or as required by law.

We will retain your Personal Information only as long as necessary to fulfill its purpose or as required by law.

Personal Information that is no longer required to fulfill its identified purpose will be destroyed, erased, de-identified or anonymized, at our option.

Accuracy

We will try to ensure that Personal Information under our control is accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used so as to minimize the risk that incorrect information is being used in relation to you. As described below, you may contact us to challenge the accuracy and completeness of, or ask us to update, your Personal Information, and have it changed as appropriate.

Safeguards

We will protect Personal Information under our control by using technical and operational security safeguards appropriate in the circumstances, taking into account the sensitivity of the Personal Information. The safeguards will protect against loss and theft, unauthorized access, use, disclosure, copying, or modification. Our officials, employees, independent contractors, and agents with access to Personal Information are required to respect the confidentiality of Personal Information. Personal Information we disclose to third parties may also be governed by protections in contracts we may have with them.

Will my Personal Information ever be transferred, stored or processed outside of Canada?

Sometimes. But your Personal Information is only provided to our suppliers and authorized agents operating outside of Canada in accordance with safeguards no less rigorous than those that we apply in Canada. Personal Information processed outside of Canada may only be used by such third parties for the purposes we set. Your Personal Information may also be subject to the legal jurisdiction of those foreign countries and also their privacy laws.

Openness

We will make readily available you information about our policies and procedures relating to our management of Personal Information.

Can I “opt-out” of the Collection, Use, or Disclosure of my Personal Information?

You can withdraw your consent or “opt-out” of the collection, use, or disclosure of your Personal Information, including where your Personal Information is being used for marketing purposes. But where your Personal Information is reasonably necessary to provide you with the products or services you requested or the operation of our business with respect to you, you cannot continue to use the products or services or our business offerings and withdraw your consent or “opt-out” of the collection, use, and disclosure of your Personal Information because it is a condition of service. To entirely stop the collection, use, and disclosure of your Personal Information, you must terminate the usage by you of our products and services and business offerings.

Use of Our Websites, Mobile Applications, and Social Media Accounts

You can visit parts of our websites, mobile applications, and social media accounts without giving us any Personal Information. However, sometimes we need Personal Information to provide products and services

If you have subscribed to any mailing or other list, and you want to be removed, please contact us to do so or select that option from the mailing or other list. You may be asked to provide certain Personal Information to confirm your identity for us to verify it is you who is asking to be removed.

Due to the nature of the internet, e-mail, text and other messaging, social medial, and the like, no data transmission is fully secure. Please be aware of this before you send us any Personal Information in any way including any of the foregoing as we cannot and do not guarantee that (and will not be liable for) any Personal Information will not be intercepted and/or misused.

“Cookies” are identifiers that a website, mobile application, or social media platform sends to your browser or mobile device and stores on your computer or mobile device to streamline your next visit to that website, mobile application, or social media platform. Cookies can estimate the number of people accessing a website, mobile application, or social media platform or account and track the pages and the like of a website, mobile application, or social media platform or account that is being visited. We may use cookies from time to time on our websites, mobile applications, and through the social media platforms we use. When we do, we use them so that we may update and improve our websites, mobile applications, and social media accounts. If you wish, you may be able to set your browser or mobile device to notify you when you are sent a cookie. In this way, you may get the option to decide whether to accept the cookie. If you choose to modify your browser or mobile device in this manner, some parts of our websites, mobile applications, or social media accounts may not function properly.

Our websites, mobile applications, and social media accounts may, from time to time, contain links to other websites, mobile applications, and social media accounts that may collect, use and disclose your Personal Information. We do not assume any responsibility for their privacy practices or policies, and cannot be held liable for the actions or inaction of those third parties. You should review the privacy policies of such parties before providing them with any Personal Information.

Contact Us if You Have Concerns and Access to Your Personal Information

By contacting us in writing at:

Computer Workware

2550 Matheson Blvd East, unit 126, Mississauga, Ontario L4W 4Z1

We will inform you of the existence, use and disclosure of your Personal Information and provide you with access to that Personal Information (within a reasonable period of time after receiving your request) and you may challenge the accuracy and completeness of, or ask us to update, your Personal Information and have it changed as appropriate. Except we may not so inform you, provide you with such access or update your Personal Information in the case of (a) information that that is prohibitively costly to provide, (b) contains references to other individuals, (c) cannot be disclosed for legal, security or commercial proprietary reasons or (d) is subject to solicitor-client privilege. In any such case, we will advise you of the reason why we cannot.

We investigate all concerns regarding compliance with this Privacy Policy. Where justified, we will take appropriate steps to resolve the concern, including, if necessary, changing this Privacy Policy and our policies and practices.

What if I Still Have Concenrs?

If we cannot resolve your concern to your satisfaction, you can contact:

Office of the Privacy Commissioner of Canada

30 Victoria Street, Gatineau, Quebec, K1A 1H3

https://www.priv.gc.ca/en/report-a-concern

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126 - 2550 Matheson Blvd E, Mississauga, Ontario L4W 4Z1

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Phone : 416.620.1704

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