KORBITEC INC.
PRIVACY POLICY

This Privacy Policy is effective as of July 1, 2019.

Korbitec Inc. (“Korbitec”, “we”, “our”, “us”) recognizes the importance of your right to privacy and wants you to be familiar with how we collect, use and disclose any personal information that individually identifies you and our commitment to meet our obligations under applicable Canadian privacy laws.

This Privacy Policy explains how we collect, use, disclose and protect your personal information when you use our website/mobile site (collectively, the “Site”) and our products, including xchangedocs (collectively, the “Products”).  This Privacy Policy is incorporated into and forms part of our Terms of Use and other related standard contracts, which outline the terms and conditions you agree to when using our Site and Products.  We will only collect, use and disclose your personal information in accordance with this Privacy Policy.

By using our Site and Products and supplying your personal information, you acknowledge that you have read and understood this Privacy Policy, and you agree and consent to the collection, use, disclosure and other processing of your personal information as outlined in this Privacy Policy.  If you do not agree to the terms of this Privacy Policy, please do not use our Site or Products or supply your personal information to us.

1.     What Personal Information do we collect?

Personal information means any information about an identifiable individual. Anonymous data means data that is not associated with or linked to any individual’s personal information or will not easily permit the identification of individuals (“Anonymous Data”). Korbitec does not consider personal information to include Anonymous Data.  The types of personal information that we may collect include, but is not limited to:

·       your name;

·       your physical address (including postal address);

·       your email address;

·       your payment information;

·       your telephone number;

·       your IP address; and

·       personal information you give us that we did not request (such as personal information you voluntarily put into an email to us).

Purposes for Collecting Your Personal Information

We collect, use and disclose your personal information in order to provide you with our Products.  We also collect, use and disclose your personal information to comply with legal and regulatory requirements and as otherwise may be permitted or required by applicable law.  We will only use the personal information that we collect for the purposes for which it was collected.  We collect your personal information for the following purposes and in accordance with applicable law:

·       when you complete your registration process for certain Products;

·       to provide you with our Products;

·       to authenticate your identity when using the Products and for account billing purposes;

·       to establish and maintain commercial relations with you, including responding to your questions;

·       to respond to questions that you send by email or through our Site;

·       to contact you about the Products, including notifying you about updates;

·       if you are using the xchangedocs Product as a document and information sharing platform, to store, process, transmit and exchange documents, pictures, spreadsheets, videos and the like with co-participants in a legal matter (“Your Artifacts“);

·       subject to applicable law, to notify you about other services and events provided by Korbitec, which may be of interest to you; 

·       to customize the appearance of the Site and Products displayed to you;

·       to obtain your feedback regarding our Products, including our surveys;

·       to track behavioral information on the Site to serve similar content upon future visits;

·       to improve the Site and Products and help us develop new services, apps, tools and Site features;

·       to support our business functions such as internal business processes, marketing and advertising; and

·       to meet any legal or regulatory requirements.

2.     When Do We Collect Personal Information?

We may collect your personal information when you voluntarily provide it to us by using our Site and Products or from third party sources. For example, we may ask you to provide personal information if you:

·       use our Site and our Products;

·       register, update or create an account on our Site and our Products;

·       sign into your account;

·       send us a question or comment by email or phone;

·       post comments or other content on our Site and our Products;

·       register to updates about our Products; and

·       otherwise participate in features of our Site and our Products that ask for personal information.

We also collect information from the devices that you use to access xchangedocs. This includes IP addresses and the type of browser and device you use and certain identifiers associated with your devices. Your devices may also transmit location information to xchangedocs.

3.     Limiting Collection of Personal Information

We limit the collection of personal information to that which is necessary to fulfill the purposes identified in this Privacy Policy and we collect, use and disclose your personal information only in accordance with this Privacy Policy.

4.     Use, Disclosure and Retention of Personal Information

Your personal information will not be used without your consent for purposes other than those for which it was collected or in accordance with applicable law. From time to time, we may wish to use personal information for new or additional purposes, in which case we will amend the Privacy Policy to include these new or additional purposes and will obtain your consent through your continued use of our Site and Products.

We may generate Anonymous Data from personal information collected through the Site and Products by removing information that makes the data personally identifiable to an individual. Such Anonymous Data includes, but is not limited to, information we collect from your use of our Site and Products.  For example, if you use the xchangedocs Product, we also collect usage information related to how you use xchangedocs, including actions taken such as uploading, sharing, downloading and viewing Artifacts. We use this information to facilitate ongoing improvements and enhancements to xchangedocs.  We also collect information from the devices you use to access xchangedocs. We may use this Anonymous Data and aggregated data for any reasonable purpose subject to applicable law.

We retain your personal information only for as long as we need it to fulfill the purposes for which it was collected, to ensure your compliance with our Terms of Service, and to comply with our legal obligations.

We may disclose your personal information to service providers, data processors and other third parties (collectively, “Third Parties”) that help with our operations and Site and Products including, without limitation, for customer services, our business operations, including monitoring and analyzing Site activity, and operating and maintaining the Site.  Such Third Parties may only use your personal information for the purposes described in this Privacy Policy.

We may also disclose your personal information in the following limited circumstances:

·       when necessary to protect our safety, property or other rights, our representatives, customers and users of the Site, including to detect and prevent fraud;

·       if we sell or transfer all or a portion of our business or assets to a related company or a third party.  Your personal information will remain subject to our pre-existing Privacy Policy unless you agree to the privacy policy of the company or third party that acquires your personal information;

·       with your consent; or

·       when otherwise required or permitted by law.

5.     Location of Personal Information

As discussed above, we may engage Third Parties to perform certain services on our behalf and to otherwise provide the Products.  We have taken commercially reasonable steps to require that these Third Parties store and process personal information on servers located in Canada.

6.     Cookies, Web Beacons and Other Similar Technology

As you interact with this Site, we may use automatic data collection technology and services that record and collect information that identifies your computer, tracks your use of this Site and collects certain other information about you and your surfing habits. This data collection technology may include cookies, web beacons and other similar devices on this Site to enhance functionality and navigation for our visitors.

A cookie is a small data file that is placed on the hard drive of your computer so that your computer will “remember” information when you visit a site.  Web beacons and tags are small strings of code that are used in conjunction with a cookie and allow us to record activity on our Site.  Internet tags, graphic tags and similar web beacon type functions allow us to count the number of users who have visited a particular web page or to access certain cookies.  We may use web beacons on this Site to count users and to recognize users by accessing our cookies. Being able to access our cookies allows us to personalize this Site and improve your experience. We may also include web beacons in HTML-formatted e-mail messages that we send to determine which e-mail messages were opened. Information tracked through these mechanisms includes, but is not limited to: (i) your IP address; (ii) the type of web browser and operating system being used; (iii) the pages of the Site a user visits; and (iv) other sites a user visited before visiting our Site.

We may also employ cookies and action tags (also known as single pixel gifs or web beacons) to collect information about your use of, and activities on, our Site for our use but also for use by third parties that serve advertisements about Korbitec on other sites you may visit.  For instance, we may use Third Party programs/services, such as AdWords run by Google Inc. (“Google”) to serve advertisements on our behalf across the Internet. These Third Party program/services may collect information about your visits to our Site. In addition to the information about your visits to our Site, Third Parties may also use the information about your visits to other sites to target advertisements for services available from Korbitec.

You can set your internet browser up so that you are notified when cookies are stored, you can decide in each individual case whether you want to accept cookies, or you can refuse to accept any cookies. However, if you do not accept cookies, you may be restricted in how you are able to use our Site. You can delete cookies that are already stored on your hard disk at any time.  You will find more details on how to do this in the operating guide for your Internet browser program.

As described above, you may be able to set your browser to refuse cookies.  If you refuse cookies you may still receive online advertising, but it may be less personalized.

7.     Security

We maintain technical, physical and administrative security safeguards to protect your personal information against loss, theft, and unauthorized access.  Any personal information that you provide to us is exchanged on a secured server. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we are committed to protecting your personal information, we cannot ensure or warrant the security of any information you provide to us.

We take reasonable steps to verify your identity before granting you access to your account on our Site. However, you are solely responsible for maintaining the secrecy of your username, password and any other account information. We also take reasonable steps to ensure that our employees are aware of the importance of maintaining the confidentiality of personal information and that unauthorized persons do not gain access to personal information that we have disposed of or destroyed. 

8.     Individual Access and Accuracy of Personal Information

You may request access to your personal information which we may hold by contacting us at the contact information set forth below, and we will respond within the time periods provided for under applicable law.  We will need to verify your identity before providing you with the personal information we hold about you. There is no cost for such access request unless you require copies of records. We may not be able to provide you with access to your personal information if the information cannot be separated from the personal information of others, cannot be disclosed for reasons of security or commercial confidentiality, or is protected by legal privilege. If we cannot provide you with access to your personal information, we will advise you of the reasons access is being denied, unless we are prohibited by law from doing so.

You may request to update and change your personal information at the contact information set forth below. We will endeavor to correct or complete any personal information which you advise us is inaccurate or incomplete.  Where appropriate, the amended information will be transmitted to third parties having access to such information.

If you are using the xchangedocs Product, you can erase or delete at any stage, all or some of your Artifacts in your xchangedocs account through your operation of the software.

9.     Electronic Communications

As part of signing up to receive the Products, you may have also opted in to receive email communications from us. If you opted-in to receive such communications, we may use the information to: communicate with you regarding our products and promotions; provide you with other information that you request; and/or improve our product and service offerings.

You will always have the opportunity to “unsubscribe” from receiving any of our e-mail or other communications at any time and we will ensure that our e-mails include instructions on how to unsubscribe if you no longer wish to receive future e-mails from us. We provide an on-going opportunity to unsubscribe or opt-out of contact by us by accessing our Site or by e-mail to dpo@korbitecinc.com or at the following telephone number: 1-800-340-3234, extension 301.

If you decide to unsubscribe, we will only contact you (i) for the purposes allowed under applicable law; (ii) to send you notices of changes to our Privacy Policy; or (iii) to receive Product related messages.

10.  Changes to this Privacy Policy

We reserve the right to change or replace this Privacy Policy at our sole discretion at any time. Please check back from time to time to ensure that you are aware of any updates or changes in this Privacy Policy. We will post the most current version on our Site and we will indicate at the top of this page the date this Privacy Policy was last revised. Your continued access or use of this Site after any such changes constitutes your acceptance of the Privacy Policy as revised.

11.  Your Consent to the Terms of this Privacy Policy

By using our Products and providing us with your personal information, you agree that Korbitec may collect your personal information and you voluntarily consent to the collection, use, disclosure and transfer of your personal information in accordance with this Privacy Policy. If you do not agree with any terms of this Privacy Policy, please do not use our Site or our Products or provide us with any personal information.  If you do not understand the nature, purpose and consequences of us collecting, using and disclosing your personal information, please do not use our Site or our Products or provide us with any personal information, and contact us at the contact information set forth below so that we can address your questions or concerns. 

Subject to legal and contractual requirements, you may refuse or withdraw your consent to certain of the purposes identified in this Privacy Policy at any time by contacting us at the contact information set forth below. If you refuse or withdraw your consent, you acknowledge that we may not be able to provide you or continue to provide you with certain services or information that may be of value to you.

12.  How to Contact Us

We welcome your feedback. If you have questions, comments or concerns about this Privacy Policy, or would like to do any of the following:

·       see your personal information that you have already sent us so that you can correct, update or delete it from our files;

·       ask that we not send you electronic communications or otherwise contact you; or

·       report any violation of this Privacy Policy,

Please contact us at dpo@korbitecinc.com or at the following telephone numbers: 416-363-1650 or 1-800-340-3234, extension 301 and we will endeavor to get back to you promptly. You may also wish to write us at the following address:

Korbitec Inc.
8 King Street East, Suite 1200
Toronto, Ontario
M5C 1B5
Attention: Privacy Officer

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