This Policy describes the practices regarding personal information collected by the Candela Strategies Ltd. (“Candela Strategies”, “we” or “us”) through our website(s) (currently, candelastrategies.com) (“Websites”) when you sign up for, use, access or otherwise interact with the Websites.
We may change this Policy from time to time. If changes are made, notification will happen by posting the updated Policy to the Websites and revising the “Updated” date. The most current version of this Policy will be effective at the time it is posted. By continuing to access or use the Websites after those changes become effective, you agree to be bound by the revised Policy.
By accessing and using any of the Websites, you acknowledge you have read and agree to be bound to all the terms of this Policy.
The Information We Collect
Personal Information. As used in this Policy, “personal information” is information about an identifiable individual, as defined in privacy laws applicable to Candela Strategies, and includes information such as your name, email address, phone number, fax number, and address.
Third Party Personal Information. From time to time our Websites may also collect personal information about third parties that you can supply in accordance with applicable laws. For instance, this may be the email address of someone you wish to inform about a document or promotion on our Websites that we may contact in accordance with applicable laws.
Additional Information. We may collect additional information than those outlined above, such as for future upgrades to the Websites, or in connection with the addition of new features and services, for which we will advise prior to collection.
Non-Personal Information. We also may collect certain non-personal information when you visit the Websites, such as the type of browser you are using (e.g., Chrome, Firefox, Safari or Internet Explorer), the type of operating system you are using (e.g., Windows 7, 8, 10, Mac OS X, iOS, Android etc.) and the domain name of your Internet service provider (e.g., Rogers, Bell, TELUS).
Personal Information of Children Under 13. We do not knowingly solicit or collect personal information from children under the age of 13. We encourage parents of children under the age of 13 to regularly check and monitor their children’s use of email and the Websites.
How We Use and Share Your Information
Personal information will only be collected, used and shared for the purposes identified at the time of collection or as outlined in this Policy. Except as described in this Section, we do not exchange, sell, rent or distribute your personal information for any purpose.
As Requested by You. We may use the information you provide about yourself to fulfill your requests for our products, programs, and services, to respond to your inquiries about our offerings, for you to participate in contests or market research, or to contact you about your account with us.
Marketing. We may use your information to communicate with you, such as to notify you about new products, programs or services, and to offer you other products, programs or services that we believe may be of interest to you, provided we have your consent to do so. Your consent to use or share your personal information for these purposes are optional and is not required as a condition of using the Websites. If you do not want your personal information to be used or shared for these additional purposes, please contact the Candela Strategies Privacy Office at the address set out below.
Third Party Service Providers. Candela Strategies may use outside service providers on Candela Strategies’ behalf to collect, use and share personal information in accordance with this Policy. These service providers are bound and subject to Candela Strategies’ privacy policies. We require all such service providers to keep your information confidential and secure and to have privacy policies and security standards with respect to personal information that are comparable to ours. We also may share other information with third parties in a manner that does not identify particular users, including, for example, aggregated information.
Legal Processes. We may disclose personal information under applicable laws, for example, in response to a court order or a subpoena. We also may disclose such information in response to a law enforcement agency’s request.
User Generated Content. User generated content posted through the Websites such as product reviews, commentary on discussion boards or blogs, and certain social networking preferences (e.g. pages you “Like” or “Recommend”) may be accessible by other consumers and companies and may appear on other websites or web searches, and therefore this information could be read, collected, and used by others. Candela Strategies cannot ensure the privacy of any user information included in that user generated content.
Social Media. To the extent you associate an account managed by third parties such as social media sites (e.g., Facebook and Twitter) with a Candela Strategies account, you authorize Candela Strategies to have access to this information and agree that Candela Strategies may collect, store and use such information in accordance with this Policy.
Disclaimer of Information Provided to Third Party Websites. In some cases we may allow you access to certain third party services by links or otherwise. Any information you provide to these third party services is not user information and will not be subject to this Policy. These links are not intended as an endorsement of or referral to the linked websites. Once you link to another site, you are subject to the privacy and security policies of the new site.
Retention. Candela Strategies will retain user information for so long as it continues to be useful in connection with providing or improving the Websites and product offerings and subject to law and this Policy. We may further retain and use data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Aggregate and De-Identified Information. We may use and share user information in aggregated or de-identified formats by removing direct personal identifiers, for internal purposes or to third parties for any purpose to the extent not prohibited by law. This Policy does not limit our use or disclosure of any aggregate or de-identified information created from user information in any way, and we reserve the right to use, disclose, and sell de-identified information (including de-identified information combined with non-scrubbed information that is not your personal information) to our partners, advertisers, and other third parties at our discretion to the extent permitted by law. “De-identified” means Candela Strategies has taken reasonable precautions to protect data de-identified from you from being re-identified to you.
Export of Personal Information. Your personal information may be processed and stored in the United States or other countries and may be accessible to the United States or other country’s government, courts or law enforcement or regulatory agencies through their laws.
How Candela Strategies Safeguards Your Information
Protection of Your Information. Candela Strategies takes precautions to secure your personal information and protect it from loss, theft, unauthorized access, destruction, use, modification, and disclosure. Such measures include technological, physical and organizational safeguards that are appropriate given the sensitivity of the personal information, including maintaining controlled access to electronic and paper documents and files, using appropriate technology safeguards such as passwords, firewalls and encryption, and restricting access to those of our employees, representatives and subcontractors who need to know such information to provide you with the services for which the information was collected. However, please note that Candela Strategies’ security measures may change or be unavailable from time to time and no data transmission over the Internet or any wireless network is 100% secure, so we cannot guarantee the security of your personal information.
Retention. Candela Strategies keeps your personal information only for as long as necessary to accomplish the identified purposes, and then securely destroys such information.
Cookies and Web Beacons
Cookies. To enhance your experience, many pages on the Websites use “cookies”. Cookies are text files we place in your computer’s browser to store your preferences or other information. Cookies, by themselves, do not tell us your e-mail address or other personal information unless you choose to provide this information to us by, for example, registering at a Website or subscribing to our newsletter. However, once you choose to furnish the Website with personal information, this information may be linked to the data stored in the cookie.
Beacons. We may also use web beacons. Beacons are small pieces of code placed on Web pages, videos, and in emails that can communicate information about your browser and device to a server. Beacons can be used, among other things, to count the users who visit a Web page or read an email, or to deliver a cookie to the browser of a user viewing a Web page or email.
Feedback, Inquiries and Complaints – Privacy Officer
If there is a concern or complaint about this Policy or your personal information, or if you wish to update or correct your information, you may contact Candela Strategies Privacy Officer at the following address:
c/o Candela Strategies
158 Sterling Road, 8th Floor
Toronto ON M6R 2B2Paragraph
Candela Strategies will respond to all inquiries, complaints or requests to access or revise personal information within a reasonable time. Candela Strategies will investigate all complaints received in a reasonable time frame and the Company will take all reasonable and appropriate measures as it determines is required to respond to any and all well founded complaints. The Company reserves the right to charge a reasonable fee in connection with complying with all lawful and permitted access requests.