Customer Expressions Corp. doing business as Case IQ
Last updated: May 6, 2023
TABLE OF CONTENTS
- PERSONAL INFORMATION WE COLLECT
- LEGAL BASES FOR PROCESSING YOUR PERSONAL INFORMATION
- COOKIES AND OTHER TRACKING TECHNOLOGIES
- OUR USE OF PERSONAL INFORMATION
- DISCLOSURE OF PERSONAL INFORMATION
- INTERNATIONAL TRANSFERS
- GENERAL AUDIENCE SITE
- GENERAL PRIVACY RIGHTS AND CHOICES
- NOTICE AT COLLECTION FOR CALIFORNIA CONSUMERS (CALIFORNIA PRIVACY NOTICE)
- NOTICE FOR VIRGINIA RESIDENTS
- CANADIAN PRIVACY RIGHTS
- CONTACT US
1. PERSONAL INFORMATION WE COLLECT
We collect personal information from our business customers, from you directly when you disclose it to us, from you automatically when you use the Services, and from third parties, as described further below. If we combine non-personal information with personal information, we will treat the combined information as personal information in accordance with applicable law.
Personal information we process for our business customers: Please note that the personal information we collect through our Services includes information that our business customers instruct us to process according to the terms of the agreement we have with them. Typically, this personal information consists of contact information such as names, email and mailing addresses, and telephone numbers; information for account administration (such as usernames and passwords); IP addresses, cookies and device information; or content information that varies based on the Services such as case management information or investigation information. Some of this information may be considered personal information or even sensitive personal information under various applicable laws. If you have questions about the processing of your personal information by our business customers, we encourage you to contact them, and they will then direct us how to respond to your request.
Personal information you disclose to us: We collect personal information that you provide to us when visiting our website, downloading our guides, using our Services, participating in activities on the Services or otherwise communicating with us. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make and the products and features you use and generally includes business contact information such as name, address, email, phone, title, company name and products or services you may be interested in. All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.
Personal information automatically collected: We automatically collect certain information when you visit, use or navigate the Services. This information may include device and usage information, such as, but not limited to, your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, general location, information about how and when you use our Services and other technical information. This personal information is primarily needed to maintain the security and operation of our Services and for our internal analytics and reporting purposes. In addition, we and third-party advertising, analytics and measurement companies may use a variety of technologies that automatically or passively collect certain personal information whenever you visit the Services or otherwise interact with us or our content, which may include the hardware model, browser, and operating system you are using, the URL or advertisement that referred you to us, the areas within the Services that you visit, the content you view and how you interact with it, your time zone, location information, and mobile network (if applicable) among other information. In some cases, we may directly collect general location information through your devices or browsers including for security and fraud prevention purposes. You may be able to turn off the collection of location information through the settings on your device.
Information From Third Parties. We may receive personal information about you from third parties, including our business customers, business partners, advertisers, analytics and measurement providers, government entities and data providers. We may also supplement the information we collect with outside records from third parties, such as public databases, publicly available Social Media pages, and third parties who enhance the information we have about you, such as if you work for a prospective business customer. We use this information to better provide our Services, to tailor our content and the offers we show you, and for other business and operational purposes. Any information collected and stored by the above third parties is subject solely to the third party’s privacy practices.
Aggregated and De-identified Data. Please note that we may de-identify or pseudonymize personal information, and there may be other exceptions such as for information that is available publicly. When we have agreed to maintain and use de-identified data without attempting to re-identify it, we will not re-identify it except where permitted by applicable law. We will treat de-identified or pseudonymized information as non-personal to the fullest extent allowed by applicable law.
2. LEGAL BASES FOR PROCESSING YOUR PERSONAL INFORMATION
We will only collect, use, disclose, and otherwise process your information with your consent, unless otherwise permitted by applicable privacy laws in your jurisdiction of residence.
If allowed by applicable privacy laws, we may process or share personal information based on the following legal bases in certain jurisdictions:
- Consent:We may process your personal information with your consent.
- Legitimate Interests:We may process your personal information when it is reasonably necessary to ensure protection of our business and security interests.
- Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
- Legal Obligations:We may disclose your personal information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
- Vital Interests:We may disclose your personal information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
3. COOKIES AND OTHER TRACKING TECHNOLOGIES
Cookies and Local Storage. Cookies and local storage are data files placed within a browser on a device when it is used to visit a Service. Certain web browsers and browser add-ons may provide additional local data storage mechanisms. Cookies and local storage can be used for a variety of purposes, including to store a unique identifier for your device that recognizes your device as you visit the Services, other sites or online services and to remember your preferences. Most browsers provide you with the ability to disable or decline cookies and local storage. You will need to check your browser’s settings for further information. If you choose to disable cookies or to adjust your privacy settings on your device, some features of a Service may not function properly. For more information about cookies and managing cookies generally, visit http://www.allaboutcookies.org.
Web Tags. Small graphic images or other web programming code called web beacons (also known as GIFs), may be included in our web pages and e-mail messages. Web tags or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to a Service, to monitor how users navigate a Service, to count how many e-mails that were sent were actually opened or to count how many particular content or links were viewed.
Beacons. Beacons are small, wireless transmitters that use low energy Bluetooth technology to send signals to other smart devices in their proximity and can be used by mobile applications to help locate a device’s physical location. We may use beacons when your device interacts with the Services and to serve you relevant advertisements.
Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Services, such as the links you click on. The code is temporarily downloaded onto your device from our server or a third-party service provider, is active only while you are connected to a site, and is deactivated or deleted thereafter.
In addition, we may use these and a variety of other technologies for security and fraud detection, to improve our products and services and to enforce our intellectual property rights.
Social Media Interactions on our Website. Our sites and applications may host or facilitate interactions with an interactive third-party website or service (“Social Media”), which may include the ability for you to “like” or “share” content. You may also have the opportunity to log in through or otherwise connect your account on a Social Media service (e.g., Twitter, Instagram, Facebook). When you interact with Social Media through our Services, we will receive information about you from that third-party service, and they may set their own cookies and collect information about your use of the Services, including your IP address or other unique identifiers such as which page you are visiting the Services. These Social Media services may be able to collect certain information about your visits to the Services regardless of whether or not you affirmatively interact with the feature and whether or not you are logged into (or have) an account with the third-party service.
4. OUR USE OF PERSONAL INFORMATION
We may use personal information collected through the Services to:
- allow you to submit information or communicate with us;
- provide customer service or technical support;
- recognize you across the Services and across devices;
- better understand our business customers and prospects;
- provide you with information, products, or services;
- investigate and prevent fraudulent transactions, possible security incidents and other illegal activities or activities that violate our policies;
- process the content that you or our business customers provide to us;
- verify your information is active and valid;
- meet disclosure obligations and other requirements imposed by or for the purposes of any laws, regulations, rules, regulations, codes of practice or guidelines binding on us (whether applicable in or outside the United States and Canada) including making disclosures to any legal, regulatory, governmental, tax, law enforcement or other authorities;
- improve our services and for internal business purposes;
- facilitate your job search via the Services and prepare related governmental and internal statistics reports;
- help you use the Services; and
- provide bookkeeping and operational purposes and notify you or for which you provide your consent.
5. DISCLOSURE OF PERSONAL INFORMATION
Business Customers: Where we are processing personal information on behalf of our business customers, we disclose personal information as directed by them. Please review their privacy policies for more information.
Service Providers/Processors: We may disclose personal information to certain service providers that we use to provide us with Services, such as information technology services, client management services, accounting, consulting, auditing and related services. We may also subcontract certain of our Services to subcontractors, subject to the terms of our contracts with our business customers.
Advertising, Social Media & Analytics Providers: We share your personal information with third parties such as advertising, social media, measurement and analytics providers for marketing, advertising and promotional purposes. For example, we may use your personal information, such as your email address, to send you news and newsletters, special offers, events, and surveys, or to contact you about services or information we think may interest you. We also use the personal information that we learn about you to assist us in advertising our products and services on third-party websites and Social Media and to assist us in evaluating the success of our advertising campaigns. We work with third parties such as network advertisers, ad agencies, analytics providers, and other advertising partners to serve ads online, to provide us with information regarding the use of the Services and the effectiveness of our advertisements. These third parties may set and access their own tracking technologies on your device (including cookies and web beacons), and they may otherwise collect or have access to Usage Information and other information about you, some of which may be personal information under various laws. Some of these parties may collect personal information over time when you visit the Services or other online websites and services.
Corporate Transactions or Events: We may disclose personal information investors and with other entities in connection with a corporate reorganization, merger, restructuring, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock, including in connection with any litigation, bankruptcy, insolvency or similar proceedings. These entities may include, without limitation, our advisors, regulators, prospective purchasers and bidders.
Legal Obligations: There may be certain legal reasons for disclosing personal information: to enforce our terms and conditions and contracts with our business customers; to protect ours and others’ rights; to protect the rights and safety of our business customers; to comply with the law, court orders or any other legal proceedings; to pursue any remedies available to us or limit damages that we may suffer; to respond to requests from public and governmental authorities, and to comply with any other relevant aspects of applicable laws from time to time.
When You Direct That We Share Your Information: We may share information when you direct us to do so. Please note that we are not responsible for the privacy practices of third parties. If you later decide that you no longer want to receive communications from a third party, you will need to contact that third party directly.
Aggregated and De-identified Information: We may disclose aggregated information for marketing, advertising, research, or any other purposes. We may share information that has been de-identified or pseudonymized with third parties in our discretion and as allowed by law, including for targeted advertising purposes.
6. INTERNATIONAL TRANSFERS
If you are accessing our Services from outside Canada or the United States, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information outside of the country where it was originally collected or outside of your country of residence or nationality. Regardless of where you live, you consent to having your personal information transferred to, processed and stored outside the United States or your province or territory of residence in Canada, and you acknowledge that such transfers may make your personal information accessible by law enforcement and security authorities of foreign jurisdictions, subject to applicable disclosure laws in those jurisdictions. The information that you provide us may be transferred around the world for the purposes of carrying out or facilitating the delivery of our Services. You may contact our Data Privacy Officer (as set out below) if you have questions or if you want to access information about our policies and practices with respect to service providers outside of Canada.
While we take steps designed to secure your personal information, no data transmission over the Internet, wireless transmission or electronic storage of information can be guaranteed to be 100% secure. Transmission of personal information to and from our Services is at your own risk. You should only access the services within a secure environment. We cannot be held responsible for loss or harm sustained by your use of our Services, as a result of any failure on your part to implement minimum technical security measures, including, but not limited to, use of a unique and hard to guess password, firewall, anti-virus programs, and/or other software to safeguard your device and/or information.
9. GENERAL AUDIENCE WEBSITE
Our Services are intended for a general audience and not for use by children, and we do not knowingly collect personal information from children. If you become aware of any personal information we have collected from a child, please contact us at email@example.com.
10. GENERAL PRIVACY RIGHTS AND CHOICES
Depending on your jurisdiction, your privacy rights may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any reasonable request in accordance with applicable data protection laws.
If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.
If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
Changing Your Information: You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information. Certain Services allow you to correct or update certain personal information you have provided. Note that when you edit your personal information or change your preferences, information that you remove may persist internally for our administrative purposes or within backup media. If you have made any public postings on a Service, these communications cannot generally be removed.
Marketing Emails and Mobile Messages: You may change your preferences of receiving marketing e-mails by following the opt-out instructions provided to you in those e-mails. Please note that we reserve the right to send you certain communications relating to your account or use of the Services, such as administrative and services announcements. These transactional account messages may be unaffected if you choose to opt out from marketing e-mails.
We may send promotional and non-promotional push notifications or alerts to your device, and may in some cases do so based on your device’s physical proximity to a beacon. You can elect to stop receiving those messages at any time by changing the notification settings on your device.
Cookies and Similar Technologies: We may use a variety of companies to serve our advertisements. Some of these companies are members of the Network Advertising Initiative (“NAI”) or the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising and you may want to visit the following webpages, which provide “opt-out” mechanisms for participating companies: https://optout.networkadvertising.org and https://optout.aboutads.info. You can opt-out from interest-based advertising on your mobile device through your mobile device settings. Please note opting out through these mechanisms does not opt you out of being served advertising and you will continue to receive generic ads while online. In addition, most browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. If applicable, you may also download the DAA AppChoices (https://youradchoices.com/appchoices) tool in order to help control interest-based advertising on apps on your mobile device). In addition, users in other countries may obtain more information at the following links: EU Users: youronlinechoices.eu (European Interactive Digital Advertising Alliance) and Canadian Users: youradchoices.ca/choices/ (Digital Advertising Alliance of Canada). Certain states provide additional rights. Please see Sections 11 and 12 below for additional rights you may have.
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. We do not currently respond to DNT browser signals.
11. NOTICE AT COLLECTION FOR CALIFORNIA CONSUMERS (CA PRIVACY NOTICE)
This California Privacy Notice is updated and effective as of April 10, 2023.
This section does not address or apply to information or practices that are not subject to the CCPA, such as:
- Publicly Available Information. Information that is lawfully made available from government records, information we have a reasonable basis to believe is lawfully made available to the general public by you or by widely distributed media, or by a person to whom you have disclosed the information and not restricted it to a specific audience.
- Deidentified Information. Information that is deidentified in accordance with applicable laws. Where we have committed to maintaining and using personal information in a deidentified form, we agree not to reidentify deidentified data except as permitted by applicable law.
- Aggregated Information. Information that relates to a group from which individual identities have been removed.
Categories of Personal Information that We Collect, Disclose, and Sell/Share.This CA Privacy Notice is directed to the scope of personal information that we collect about California residents in our capacity as a Business and not as a Service Provider. While our processing of personal information varies based upon our relationship and interactions with you, this CA Privacy Notice is focused on our collection and use of personal information from business contacts and website visitors to the extent that we collect such personal information that is subject to the CCPA. The categories of personal information we collect from our business customers in our role as a Business include:
- Identifiers such as business contact information including name, alias, email and physical address, job title, company, unique personal identifiers, online identifiers, Internet Protocol (IP) address, account name, or similar information;
- Internet or Other Electronic Network Activity Information such as information regarding browsing history, clickstream data, search history, and your interaction with our websites or advertisements, including access logs and other activity information related to the use of our products and services; and
- Profiles and Inferences such as inferences drawn from other personal information that we collect to create a profile reflecting an individual’s preferences and purchase tendencies.
Categories of Third Parties. We disclose the categories of personal information listed above to advisors and agents; government entities and law enforcement; advertising networks; data analytics providers; social networks; internet service providers; operating systems and Services; service providers; and others as permitted by law.
Purposes for Collecting, Using, Disclosing, and Processing Personal Information. As more fully described above, we collect, use, and otherwise process the above categories of personal information for the following business and commercial purposes: general operations, business services and support; analytics, measurement and improvement; customization and personalization; marketing and advertising; planning and managing events; research and surveys; security and protection of rights; legal proceedings and obligations; corporate transactions or events; transactional and payment purposes, customer service and communications, legal compliance and protection of us and others in furtherance of legal obligations and other purposes.
Sale and Sharing of Personal Information. Although we do not monetize your personal information (e.g., we do not sell customer lists to other entities for money), we do disclose the following categories of personal information: identifiers, profiles and inferences, and internet or other electric network activity information to third-party advertising networks, analytics providers, and social networks for purposes of marketing and advertising; analytics, measurement and improvement; and customization and personalization, which could be deemed to be a sale or sharing under CCPA (e.g., we may permit such providers to place a cookie, tag, or other tracking tool on our website to assist us with our advertising, and these providers also may use your personal information to assist other companies with their online advertising, analytics and personalization as well). We do not sell or share any personal information about individuals who we know are under sixteen years old.
Sources of Personal Information. As further described above, we collect personal information from the following sources: directly from you; advertising networks; data analytics providers; social networks; internet service providers; operating systems and Services; Group Companies; partners; and government entities.
Retention. We retain the personal information we collect only as reasonably necessary for the purposes described above or otherwise disclosed to you at the time of collection. For example, we will retain transactional data for as long as necessary to comply with our tax, accounting and recordkeeping obligations, and as necessary to protect, defend or establish our rights, defend against potential claims, or comply with legal obligations.
Your Rights. The CCPA provides you with certain rights regarding your personal information. This section describes those rights and how to exercise them. Please note that these rights are subject to certain conditions and exceptions:
- Right to Know/Request Access. With respect to the personal information we have collected about you, you have the right to know the: categories of personal information we collected about you; the categories of sources from which we collected your personal information; the business or commercial purposes for collecting, selling, or sharing your personal information; the categories of third parties to whom we have disclosed your personal information; and the specific pieces of your personal information we have collected.
- Right to Delete. You have the right to request we delete your personal information.
- Right to Correct. You have the right to request that we correct inaccuracies in your personal information.
- Right to Opt-Out of Sales and Sharing. You have the right to opt-out of sales and sharing of your personal information, as those terms are defined under the CCPA, including using an opt-out preference signal as described below.
- Right to Limit the Use of Your Sensitive Personal Information. If we collect sensitive personal information and use it for purposes other than to provide you certain services or as provided under the CCPA, you have the right to limit the use of your sensitive personal information. At this time, we do not collect this information so the right to limit does not apply.
- Right to Non-Discrimination. We will not discriminate against you for exercising any of the rights described in this section.
Authorized Agents. You may designate someone as an authorized agent to submit requests and act on your behalf. Authorized agents will be required to provide proof of their authorization, and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.
Exercising Your Rights. If you are a California resident and would like to exercise your CCPA rights, you may do so by:
- Emailing us at firstname.lastname@example.org
- Calling us at 1-800-465-6089 (toll free)
- Writing to us at: ATT: Data Privacy Officer, 300 March Road, Suite 501, Ottawa, ON, Canada K2K 2E2
We also honor your right to opt out of sales and sharing as signaled by a universal opt out signal or Global Privacy Control (“GPC”). To enable GPC, you can visit the Global Privacy Control page at https://globalprivacycontrol.org. If you download a supported browser or extension and exercise your privacy rights with GPC, we will turn off third-party advertising cookies on our website once our website detects a GPC signal. If you visit our website from a different device or from a different browser on the same device, you will need to opt-out, or use an opt-out preference signal, for that browser and/or device.
Financial Incentives. A business may offer financial incentives for the collection, sale or deletion of California residents’ personal information, provided the incentive is not unjust, unreasonable, coercive or usurious, and is made available in compliance with applicable transparency, informed consent, and opt-out requirements. California residents have the right to be notified of any financial incentive offers and their material terms, the right to opt-out of such incentives at any time, and may not be included in such incentives without their prior informed opt-in consent. We do not offer any financial incentives at this time.
Changes to this CA Privacy Notice. This CA Privacy Notice will be updated from time to time. We will post any updated CA Privacy Notice to our website.
12. NOTICE TO VIRGINIA RESIDENTS.
Virginia Consumers have the following rights, subject to the exceptions set forth in the VCDPA:
- Right to Know: The right to confirm whether we are processing your personal information and request to access such data.
- Right to Correct: The right to correct inaccurate personal information we hold about you.
- Right to Delete: The right to delete the personal information provided by you or obtained about you.
- Right to Obtain: The right to obtain a copy of the personal information previously provided by you to us and, to the extent feasible, in a readily usable format to allow data portability.
- Right to Opt-Out of Targeted Advertising: To right to opt-out out of the processing of your personal information for the purposes of targeted advertising. See General Privacy Rights and Choices above.
If you are a Virginia Consumer and would like to exercise your rights pursuant to the Virginia Consumer Data Protection Act (“VCDPA”), and any implementing regulations adopted thereunder, please submit a request to: email@example.com with the details of your request. Alternatively, you can write to us at the following address: Data Privacy Officer, 300 March Road, Suite 501, Ottawa, ON, Canada K2K 2E2.
VCDPA Appeals: Pursuant to the VCDPA, if you would like to appeal our decision relating to your request, you have the right to submit an appeal by contacting us as described above.
13. CANADIAN PRIVACY RIGHTS
If you contact us via telephone, the call may be recorded for quality and security purposes and so that we can respond to your request.
You may instruct us to refrain from using your personal information in any way that is not required for us to provide the Services to you. We will not refuse you access to any product or service merely because you have advised us to stop using your personal information in any way that is not required for the Services. Conversely, if you do not consent to the collection of certain personal information, we may be unable to provide certain services to you.
If you demonstrate the inaccuracy or incompleteness of your personal information, we will amend the information as required. If appropriate, we will send the amended information to third parties to whom the information has been disclosed. When a challenge regarding the accuracy of personal information is not resolved to your satisfaction, we will annotate the personal information under our control with a note that the correction was requested but not made.
Upon written request to our Data Privacy Officer, and authentication of your identity, we will provide you your personal information under our control. We will also give you information about the ways in which that information is being used and a description of the individuals and organizations to whom that information has been disclosed. We may charge you a reasonable fee for doing so, where permitted by applicable law.
In some situations, we may not be able to provide access to certain personal information (e.g., if disclosure would reveal personal information about another individual, the personal information is protected by solicitor/client privilege, the information was collected for the purposes of an investigation or where disclosure of the information would reveal confidential commercial information that could harm our competitive position). We may also be prevented by law from providing access to certain personal information. Where an access request is refused, we will notify you in writing, document the reasons for refusal and outline further steps which are available to you.
We will keep personal information used to make a decision affecting you for at least one year after using it to make the decision. We will destroy, erase or make anonymous documents or other records containing personal information once it is reasonable to assume that the original purpose is no longer being served by retention of the information and retention is no longer necessary for a legal or business purpose.
If you are a resident of the province of Quebec or are otherwise subject to the Quebec Act respecting the protection of personal information in the private sector, there are additional rights available to you in addition to those listed above:
- You can request data portability, meaning that you have the right to receive a copy of your personal information in a structured, commonly used and machine-readable form and, if technically feasible, to transfer such personal information to another party at your request; and
- You can request deindexation of your personal information, meaning that, under certain circumstances, you can ask that we cease to disclose any of your personal information or that we deindex any hyperlink associated with your name and allowing to access your personal information, if such disclosure is prohibited by law or otherwise deemed harmful.
15. CONTACT US