Georgian is committed to protecting your privacy when you interact with this website.
If this Policy changes in the future, we will post an updated version on our Site at https://georgian.io/privacy-policy/. We recommend that you check this Site periodically in order to review our current Policy. You can tell if this Policy has changed by checking the effective date that appears at the bottom of this Policy.
By using this website (Site), you consent to the terms of our Policy and to Georgian’s collection, use and disclosure of Personal Information as outlined below.
If you are a user or visitor in the European Economic Area, the EU General Data Protection Regulation (GDPR) also applies to the processing of your information. The GDPR places obligations on us as a “data controller” and grants you specific rights in respect of the use and handling of your Personal Information. Both Personal Information and personal data have the same meaning in the context of this Policy.
PERSONAL INFORMATION WE COLLECT
We may require you to provide us with Personal Information if you would like to participate in some activities available on, or benefit from services offered on, this Site. We endeavour to limit our requests for your Personal Information to information we believe is minimally necessary to achieve our stated collection purposes.
When you contact us or sign up to receive our newsletters and other communications, you voluntarily give us certain Personal Information including your e-mail address which we collect.
When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages, products, or services that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information”, which may be combined with other information and could be used to identify you.
We collect Device Information using cookies, log files, web beacons, tags and pixels. Below is information about the technologies mentioned above:
- “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
- “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
- “Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Site.
When we talk about “Personal Information” in this Policy, we are talking both about Device Information and information you knowingly provide to us.
HOW DO WE USE YOUR PERSONAL INFORMATION?
We take your privacy seriously. We may collect, use and disclose your Personal Information to communicate with you, personalize your experience with the Site, and when in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.
We use the Device Information that we collect (in particular, your IP address) to help us screen for potential risk and fraud, and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).
At any time you can contact us to: stop receiving e-mails from us; review the Personal Information held by us about you; withdraw your consent for our use and disclosure of your Personal Information; and amend your Personal Information, where possible.
SHARING YOUR PERSONAL INFORMATION
We may share your Personal Information with third parties, but only as necessary to provide and make improvements to this Site and our associated services. For example, we may share your Personal Information with contact enrichment services such as Clearbit to pre-populate form fields, reducing typing effort for you when appropriate.
In addition, we may share information with third parties on an anonymous or aggregated basis such that any individual would not be able to be identified and no Personal Information is shared. We may remove personal identifiers from your information and maintain and use it in an aggregate form that may later be combined with other information to generate anonymous, aggregated statistical information.
If our Company is to be sold, merged or amalgamated or substantially all of its assets are to be sold or disposed of, your Personal Information may be transferred to a potential purchaser if, and to the extent necessary, it is required for the purposes of deciding whether to proceed with the proposed transaction and completing it. If such a sale, merger, acquisition or disposal is completed, the purchaser may use and disclose your Personal Information only to the extent described in this Policy if the information relates solely to the carrying on of the business or activity or the carrying out of the objects for which the sale, merger or acquisition took place.
Finally, we may also collect, use, or disclose your Personal Information without your knowledge or consent in compliance with laws or regulations to: respond to a valid subpoena, order, or government request; establish or exercise the Company’s legal rights or defend against legal claims; investigate, detect, supress, prevent or take action regarding illegal or prohibited activities, suspected fraud, situations involving potential threats to the reputation or physical safety of any person; for processing and other similar administration purposes; or as otherwise required by law.
As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
You can opt out of targeted advertising by visiting the following websites to modify your preferences:
FACEBOOK – https://www.facebook.com/settings/?tab=ads
Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at http://optout.aboutads.info/.
DO NOT TRACK
Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.
YOUR RIGHTS / ACCESS TO AND CORRECTION OF YOUR PERSONAL INFORMATION
You have a right, subject to certain exceptions, to access Personal Information we hold about you and to ask that your Personal Information is corrected, updated, deleted, or have your consent withdrawn. Requests for access or correction must be in writing and made through the contact information below.
Additionally, we may process your Personal Information in order to pursue our legitimate business interests listed above.
We will retain your Personal Information only for a time and only to the extent necessary for the purposes for which it was collected as described in this Policy and for reasonable backup, archival, audit, or other similar purposes.
You may update your communication preferences anytime by contacting us as set out below. Georgian provides you with the opportunity to exercise an opt-out choice if you do not want to receive emails from us or updates regarding new services and products offered on this Site. The opt-out choice may be exercised upon receipt of an email from Georgian. You can always unsubscribe from receiving promotional e-mails from us by simply clicking the “unsubscribe” link provided at the bottom of every promotional Company e-mail from us or by emailing email@example.com with the subject line: Opt-out. We will process your unsubscribe as soon as possible, but please be aware that in some circumstances you may receive a few more messages until the unsubscribe is processed.
You may view and manage any personal data and consent information we have collected about you and on the Privacy Tools page.
We may update this Policy from time to time to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons. Any changes will be communicated to you via email or notice on our Site.
Georgian endeavors to take commercially reasonable and appropriate steps to protect your Personal Information from unauthorized access or disclosure. However, we do not warrant or represent that your Personal Information is completely safe from hackers and other security threats.
We aim to provide you with a safe experience. We have in place certain physical, electronic, technological, and organizational safeguards to appropriately protect the security and privacy of your Personal Information against loss, theft, and unauthorized access, disclosure, copying use or modification. Please note, however, that while we try to create a secure and reliable Site for users, the confidentiality of any communication or material transmitted to or from the Site or via e-mail cannot be guaranteed.
We limit access to your Personal Information within the Company to individuals on a need-to-know basis.
Your Personal Information may be transferred, processed and retained on servers in countries outside of Canada, including in the United States, and may therefore be subject to laws that do not offer the same degree of protection as Canadian law, although the Company will ensure that contractual protections, at least equal to its own standards, are put in place with those third-party providers located outside Canada. While we undertake to protect your Personal Information when it is transferred to other jurisdictions, the laws of other jurisdictions may require the disclosure of your Personal Information to governmental authorities under circumstances that are different than those that apply in Canada and are contemplated under this Policy.
LINKS TO OTHER SITES
ADDITIONAL RIGHTS OF EU DATA SUBJECTS
If you are an EU data subject, under the GDPR, without limitation, you have the following additional rights in respect of your information:
- you are entitled to ask us to port your Personal Information (i.e., to transfer it in a structured, commonly used, and machine-readable format to you), to erase it, or restrict its processing;
- you have the right to object to some processing of Personal Information that is based on our legitimate interests, such as profiling that we perform for the purposes of direct marketing;
- you may withdraw any consent we have requested and/or that you have provided in respect of the processing or handling of your Personal Information; and
- if you have unresolved concerns regarding the use or handling of your Personal Information you have the right to complain to data protection authorities. The relevant data protection authority will be the data protection authority of the country: (i) of your habitual residence; (ii) of your place of work; or (iii) in which you consider the alleged infringement has occurred.
There are limitations on these rights in certain circumstances, for example (and without limitation):
- if we can demonstrate that we have a legal requirement to process your Personal Information, then in some instances we may retain data even if you withdraw consent; and
- if we require your Personal Information to comply with legal or contractual obligations, and if without such data we will not be able to manage our contractual relationship with you, or meet any obligations placed on us, then provision of such data is mandatory.
If you have any questions about the Policy, or need to provide notice to, or communicate with, Company under the Term of Use, please contact us by clicking Contact Us, by calling us at (416) 868-9696, by emailing us at firstname.lastname@example.org or by mail to the Company at: Privacy Officer
2 St Clair Ave West, Suite 1400
Effective Date: June 25, 2018