CHAORDIX PRIVACY POLICY

Last Updated: April 22, 2021

ABOUT THIS POLICY

This Privacy Policy describes how Chaordix Inc (“Chaordix”/”we”/”us”) collects, uses, shares, and handles personal information about individuals who use this website, www.chaordix.com and/or the subsites hosted by us (the “Website”) and about users of our services provided in connection with our community platform which enables brands to connect to their communities (the “Services”).  Chaordix is committed to abiding by data protection laws and to be transparent in how we use personal information of users of our Website and/or Services (each a “User” and collectively “Users”).

This Privacy Policy also describes in general terms how we handle Personal Information (as defined below) on behalf of our customers.  However, this Privacy Policy does not set out the information collected in individual communities which are subject to the privacy policies of the community owner.   When Chaordix handles Personal Information on behalf of one of our customers/community owners, we are doing so pursuant to the customer’s instructions as their data processor. If you want to know more details about that customer’s data protection policies, you should consult the customer’s privacy notice.  Accordingly, any access or correction requests or similar requests from members of communities will be directed to the customer/community owner who created that community.

If you have questions or concerns about anything in this Privacy Policy, our Data Protection Officer may be contacted using the contact details set out at the bottom of this Privacy Policy.

INFORMATION WE COLLECT ABOUT USERS

The term “Personal Information” or “Personal Data” has the meaning given under applicable law but essentially, it means any information about any individual who is or can be directly or indirectly identified from such information.  Personal Information does not include data which cannot be related to an identifiable living person (eg. anonymous data).

We may collect, use, store and transfer different kinds of Personal Information about Users which we have grouped together as follows:

•       Identity Data which may include first name, last name or similar identifier.

•       Contact Data which may include email address and telephone numbers.

•       Technical Data includes internet protocol (IP) address, browser type and version, operating system and platform.

•       Usage Data includes information about how Users use our Services, such as browsing actions within the community, the buttons and controls a User clicks on, pages within our communities that a User visits, the time spent on those pages, a User’s search queries and the dates and times of a User’s visit(s).

We also collect, use and share non-personally identifiable data called “Service Data” such as statistical or demographic data for any purpose. Service Data may be derived from a User’s Personal Information but is not considered personal information in law as this information does not directly or indirectly reveal a User’s identity. For example, we may aggregate a User’s Usage Data to calculate the percentage of Users accessing a specific website feature.

We do not collect any Special Categories of Personal Data about Users (this includes details about Users’ race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about Users’ health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.  In addition, Chaordix does not intentionally collect protected health information, financial information, social security or other government-issued identification numbers from Users.

Choice

It is always a User’s choice whether or not to provide Personal Information. However, if a User chooses not to provide requested Personal Information, that User will not be able to use certain features of the Services. We set out in detail below the information that we collect about Users and Users’ use of our Services.

HOW WE COLLECT PERSONAL INFORMATION

We use different methods to collect data from and about Users including through:

•       Direct interactions. Users may give us Identity, Contact and Profile Data by registering for the Services and completing fields within the Services.

•       Automated technologies or interactions. As Users interact with our Services, we may automatically collect Technical Data and Usage Data about a User’s equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.

•       Third parties or publicly available sources. We may receive personal information about Users from various third parties and public sources including Technical Data from the following parties:

•       analytics providers such as Google Analytics;

•       search information providers such as Google.

HOW WE USE PERSONAL INFORMATION

We have set out below, in a table format, a description of all the ways we plan to use Users’ personal information.

Purpose/Activity

Type of Data

To deliver the Services to Users (including by recognizing users across the devices they use, and providing, maintaining, tailoring and improving website and services)

  • Identity Contact
  • Profile
  • Usage
  • Technical

To register Users

  • Identity
  • Contact

To manage our relationship with Users which will include Notifying Use about changes to our terms or Privacy Policy

  • Identity
  • Contact

To administer and protect our business and this the Service (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

  • Identity
  • Contact
  • Technical

To use data analytics to improve our services, customer relationships and experiences and to personalize our Services

  • Technical
  • Usage

To make suggestions and recommendations to User about services that may be of interest to Users and to provide Users with information, products or services they request

  • Identity
  • Contact
  • Technical
  • Usage
  • Profile

To improve our Services including:

a)     tracking email open rates, web page visits and form submissions

b)     To inform Chaordix as to what content is effective

c)     To provide follower updates

d)     To personalize the Services

  • Identity Contact
  • Profile
  • Usage
  • Technical

Disclosures

We may disclose Personal Information that we collect, or Personal Information which Users provide as described in this Privacy Policy:

•       To our subsidiaries and affiliates where they are providing aspects of the Services.

•       To contractors, service providers, and other third parties we use to support our business solely for the purpose of them providing services to us.

•       To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Chaordix’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by Chaordix about our Website or any software applications we make available where users is among the assets transferred.

•       To fulfill the purpose for which Users provide it.

•       For any other purpose expressly disclosed by us when Users provide the information.

•       With Users’ express consent to other uses not indicated in this Privacy Policy.

We may also disclose Users’ Personal Information:

•       To comply with any court order, law or legal process, including to respond to any government or regulatory request.

•       In connection with our data processing agreement with customers who operate any community that a User is or has been a party to.  

•       If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Chaordix, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection.

ACCESS REQUESTS

Upon request, Chaordix will provide Users with information about whether we hold any of a User’s Personal Information. Chaordix enables customers and website visitors with the ability to access and correct Personal Information we have collected. If Users have any concerns or suspect unauthorized activities associated with User’s account, please contact us at privacy@chaordix.com.  We will respond to Users’ requests within a reasonable timeframe, and in any event within 30 days of receipt of a request. 

Chaordix acknowledges that Users have the right to access, update, revoke permission to process, or request the deletion of User’s Personal Information. Any such query can be directed to Chaordix’s Data Protection Officer at privacy@chaordix.com.  If requested to remove data under either scenario, we will respond within a reasonable timeframe. 

Please note that access and deletion requests in relation to Personal Information collected, used and otherwise handled in individual communities should be directed to the community owner in accordance with their own privacy policies.  

SECURITY AND ENFORCEMENT. 

The security of Users’ Personal Information is important to us. We use security safeguards appropriate to the sensitivity of the information to ensure that Users’ Personal Information is stored and maintained in a secure environment. Chaordix exercises managerial and technical safeguards designed to protect against the loss or unauthorized use or disclosure of Personal Information belonging to our customers and website visitors. These safeguards include encryption, malware protection, logical and physical access controls, and detection of social engineering attacks.

Chaordix monitors and reviews security safeguards and takes corrective action whenever we discover deviations from our Privacy Policy.

ONLINE COLLECTION OF ADDITIONAL DATA; AUTOMATIC DATA COLLECTION

As Users navigate through and interact with our Website and Services, we may use automatic data collection technologies to collect certain information about Users’ equipment, browsing actions and patterns, location, and workplace usage patterns, including:

•       Details of Users’ visits to our Website and other communication data and the resources that Users access and use on the Website.

•       Information about Users’ computer and Internet connection, including Users’ IP address, operating system, and browser type.

•       We also may use these technologies to collect information about User’s online activities over time and across third-party websites or other online services (behavioral tracking) in connection with the use of our Website.

•       We may collect information about Users’ mobile device and Internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information and the device’s telephone number.

We and our third-party service providers may collect information about Users in a variety of ways. We and/or our third-party partners may employ various tracking technologies, such as cookies, web beacons and analytics software, that help us better manage content on our Services by informing us what content is effective.

Cookies. 

When Users visit our Website or otherwise interact with the Services, we (or third-party data or ad networks we work with) may send one or more “cookies” to a User’s computer or other devices. Cookies are alphanumeric identifiers stored on a User’s computers through a User’s web browser(s) and are used by most websites to help personalize a User’s web experience. Some cookies may facilitate additional site features for enhanced performance and functionality such as remembering preferences, allowing social interactions, analyzing usage for site optimization, providing custom content, allowing third parties to provide social sharing tools, and serving images or videos from third-party websites. Some features on this site will not function if Users do not allow cookies. We may link the information we store in cookies to any Personal Information Users submit while on our Website.

We may use both session cookies and persistent cookies. A session cookie expires when a User closes their browser. A persistent cookie remains on a User’s hard drive for an extended period of time. Persistent cookies enable us to track and target the interest of our users to enhance the experience on our site. If Users do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows Users to automatically decline cookies or be given the choice of declining or accepting the transfer to a User’s computer of a particular cookie (or cookies) from a particular site. Users may also wish to refer to http://www.allaboutcookies.org/managecookies/index.html. If Users reject cookies, Users may still use our Website, but some features on the site will not function properly.

Functional cookies, persistent and session type, store information to enable core site functionality.

Analytics cookies allow us to count page visits and traffic sources, so we can measure and improve the performance of our site and our marketing campaigns.

Web Beacons

We (or third-party data or ad networks we work with) may use Web Beacons alone or in conjunction with cookies to compile information about our Service, or other information we or they have collected. Web Beacons are tiny graphic objects that are embedded in a web page or email and are usually invisible to the user but allow checking that a user has viewed the page or email. Web Beacons may be used within the Service to track email open rates, web page visits or form submissions. In some cases, we tie the information gathered by Web Beacons to our Users’ Personal Information. For example, we use clear gifs in our HTML-based emails to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns.

HTML5 Storage

We use Local Shared Objects, such as SessionStorage, Local Storage AND/OR HTML5, to store content information and preferences. Third parties with whom we partner to provide certain features on our Website regarding Users’ web browsing activity also use Flash cookies or HTML5 to collect and store information. Various browsers may offer their own management tools for removing HTML5.

Do Not Track Signals

At this time, browser ‘do not track’ signals are not supported.

TRANSFERS OF DATA 

Chaordix’s headquarters in Canada is our primary location for business operations.  Servers hosting the Chaordix platform are located in Oregon United States, Dublin Ireland and Sydney Australia and for community members’ data, the location of storage is based on decisions made by the community owner.

In order to provide Users with the information, products, or services that Users have requested, Personal Information may be transferred or shared with other companies within our family of companies, including those third-party vendors who act on our behalf, process Personal Data in accordance with the purposes for which the data was originally collected, or for purposes to which Data Subjects have subsequently consented. Our Privacy Policy, supported by contractual agreements and safeguards for data governance, are designed to provide equivalent data protection for all customers wherever they may reside.  For example, regarding normal business operations, Chaordix may engage a third-party to support our billing, support services, information technology, or mailings on our behalf.

We may also transfer Personal Information as required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect User’s safety, or the safety of others, investigate fraud, or respond to a government request.

THIRD PARTY SITES

Through the Website or Services, you may be introduced to a variety of third-party vendors and/or websites. The privacy policies of these third parties are not under our control and may differ from ours. The use of any information that Users may provide to any third-party, or the use of “cookie” technology by any third-party, will be governed by the privacy policy of the operator of the website that Users are visiting.  The privacy policies of these third parties are not under our control and may differ from ours. If Users have any doubts about the privacy of the information Users are providing on another website, we recommend that Users contact that website directly for more information and review its privacy policy.

DATA RETENTION

Chaordix will keep Users’ Personal Information for as long as it remains necessary for the purpose identified in this Privacy Policy or as required by law, which may extend beyond the termination of our relationship with Users. Users acknowledge and agree that if User request that User’s name be removed from our databases, it may not be possible to completely delete all Users’ Personal Information due to legal constraints.  In addition, the premature deletion or destruction of certain data could be prejudicial to our ability to address claims, deal with operational difficulties or meet regulatory or legal obligations.  Accordingly, we may retain certain data (which may include personal Information) (in order to fulfil our contractual, statutory or regulatory requirements and/or to meet our operational needs and to preserve information which has historic value.  Our records must be stored in a safe, secure, and accessible manner. All electronic documents and files that are essential to our business operations must be duplicated and/or backed up regularly.  For all other data which is not deemed essential Chaordix aims to utilize appropriate systems for the timely and secure disposal of documents and records that are no longer required for business purposes. 

CALIFORNIA RESIDENTS’ PRIVACY RIGHTS

California consumers have the right to request to know more details about the categories or specific pieces of Personal Information we collect (including how we use and disclose this Personal Information), to delete their Personal Information, to opt out of any “sales” or “sharing” of Personal Information that may be occurring, and to not be discriminated against for exercising these rights.  California consumers may make a request pursuant to their rights under the CCPA by contacting us at the contact information below. We will verify your request using the information associated with your account, if available, including email address. Government identification may be required. Consumers can also designate an authorized agent to exercise these rights on their behalf.

EEA PRIVACY RIGHTS

If you are a resident of the EEA, you have certain data protection rights. We take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Information (known as “Personal Data” under the EU General Data Protection Regulation).

If you wish to be informed of what Personal Data we hold about you and if you want it to be removed from our systems, please contact us using the contact information set out below. Note that where we act as the data processor on behalf of our users, you will be required to contact the data controller directly to exercise your rights.

In certain circumstances, where we act as data controller, you have the following data protection rights:

•               Request access to your Personal Data (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Information we hold about you where we are the data controller and to check that we are lawfully processing it.

•               Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us.

•               Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

•               Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

•               Request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios: (a) if you want us to establish the information's accuracy; (b) where our use of the information is unlawful but you do not want us to erase it; (c) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.

•               Request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

•               Withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.  

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the EEA. 

If you wish to exercise any of the rights set out above, please contact us using the contact details below. 

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.  We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it.  We may also contact you to ask you for further information in relation to your request to speed up our response.

NOTICES

Chaordix may make changes to this Privacy Policy from time to time for any reason. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used. If we make any material changes or changes in the way we use information, we will notify via e-mail or by posting the updated version of the Privacy Policy on the Website. Users are bound by any changes to the Privacy Policy after such changes have been posted.  In the event that Chaordix is involved in a merger, acquisition or asset sale, we will continue to ensure the confidentiality of any Personal Information and give affected users notice before Personal Information is transferred or becomes subject to a different privacy policy. Account holders will be notified via email and/or a prominent notice on our Website of any change in ownership or uses of Users’ information, as well as any choices Users may have regarding their information.

CONTACT US

Write to our Data Protection Officer at the following address or send us an email to the email address set out below:

Chaordix Inc.

Suite 2300, 150-9th Ave SW, Calgary, AB, T2P 3H9, Canada

privacy@chaordix.com

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