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OUR PRIVACY POLICY

Effective date: May 17, 2018

The short version:

At InitLive Inc. (“InitLive”), we are committed to protecting your privacy, and maintain a general policy of openness about how we collect, use and disclose your personal information in connection with the services (“Services”) that we offer through our online platform which is accessed through our websites initlive.com and app.initlive.com (together, “Website” or “Site”) and our mobile applications (“Apps”).

Through the Service, your information is used for event scheduling management at events organized and/or administered by the Event Manager(s), either where you are or are acting for the Event Manager or where you agree to be part of that Event Manager’s Events.

We only collect the minimum amount of personal information that is necessary to fulfill the purpose of your interaction with us and with Organization(s).  We don’t sell your information to third parties, and we only use it as this Privacy Policy describes. If you are visiting from the EU, we comply with GDPR.

Please read on for more details.

The purpose of this Privacy Policy is to inform you about InitLive’ practices relating to the collection, use, disclosure and protection of personal information that may be provided through access to or use of our Services and our Website or that may otherwise be collected by us. BY USING OUR SERVICES OR OUR WEBSITE YOU AGREE TO THE COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION (AS DEFINED BELOW) IN ACCORDANCE WITH THE FOLLOWING TERMS AND CONDITIONS. DEFINED TERMS IN THIS PRIVACY POLICY WILL HAVE THE SAME MEANING AS IN OUR TERMS OF USE UNLESS OTHERWISE DEFINED IN THIS PRIVACY POLICY.

This Privacy Policy also explains how you can contact us if you have a question about, want to make a change to or want to delete any personal information that InitLive may be maintaining about you. We strongly recommend that you take the time to read this Privacy Policy and retain it for future reference.

1. WHY WE COLLECT, USE OR DISCLOSE YOUR PERSONAL INFORMATION, AND WHETHER WE ACT AS DATA CONTROLLER OR DATA PROCESSOR

We collect, use and disclose your personal information in order to provide you with our Services, including allowing you to interact with other users of our Services, whether they are Participants or Event Managers. By using the Service, you agree to the collection and use of information in accordance with this policy.

We may act as either a Data Controller or as a Data Processor when we collect, manage, use and disclose your personal information. We act as a Data Controller where you register an account with us and where you provide information to basic us regarding you or your account. If you are a Participant who is engaged by or interacts with an Event Manager through the Service, we act as a Data Processor on behalf of that Event Manager in respect of any information that you provide to that Event Manager through our Services.  


2. WHAT PERSONAL INFORMATION IS COLLECTED THROUGH THE SERVICES

For the purpose of this Privacy Policy, and in accordance with Canadian and EU privacy legislation, “personal information” is generally defined as any information relating to an identifiable individual who can be directly or indirectly identified in particular by reference to an identifier.

The personal information collected by InitLive upon using our Services or our Site may include at least some of the following, detailed by how and when it is collected:

2.1 Registering for an account:

When you register for an account with us, we will collect the following types of information for the purpose of administering your account:

    • Contact information, including name and e-mail address;
    • If you are registering as an Event Manager, we may also ask for Billing information and credit card number only when you provide it in order to access the InitLive services;
2.2 Information that you can provide to better use the Services

When you register for an account with us, we will also invite you to edit your profile by submitting the types of information set out below. These are for the purpose of allowing you to provide more detailed information about yourself as a potential Participant to Event Managers:

    • Date of birth,
    • gender,
    • biography
    • t-shirt size,
    • emergency contact name
    • emergency contact information;
    • Address

Some Event Managers may require you to submit some or all of this information in order to participate in their Event. If you submit this type of information at the request of an Event Manager we may nonetheless continue to store and use this information as part of your general profile information, which may be viewed by any Event Manager.  

2.3 Personal Information requested or stored by Event Managers.

When you register as a Participant with an Event Manager, the Event Manager may use the Service to request, access, store and process additional personal information such as:

    • Answers to customised questions created by the Event Manager;
    • Performance evaluation;
    • Scanned and/or uploaded documentation including, but not limited to, resume, safety/first aid accreditation, security clearance and police check;
    • Checking in and checking out of Events;
    • Communications through the Services;
    • Location; and
    • Such other information as we may clearly inform you of through the Services from time to time.
2.4 Usage Data

We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device ("Usage Data").

This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access the Service by or through a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

2.5 Additional Information

From time to time, we may ask you to provide us with more detailed information regarding your interests in order to serve you better and understand what features and services may be of interest to you. It will be entirely up to you as to whether you choose to share this information with us. When you provide us with your personal information, we will inform you as to why we are collecting it.

Also, if you send us an e-mail message, we may retain that message and your e-mail address, as well as any response we send you.

2.6 Tracking Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and hold certain information.

Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

  • Session Cookies. We use Session Cookies to operate our Service.
  • Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
  • Security Cookies. We use Security Cookies for security purposes.
  • Advertising Cookies. Advertising Cookies are used to serve you with advertisements that may be relevant to you and your interests.
     
3. HOW WE USE YOUR PERSONAL INFORMATION

We use your personal information to:

    • Provide you with the Services including:
      • Allowing you to administer your own account (as a Participant) and that of an Event Manager (where you are registered as and authorised to act on behalf of an Event Manager)
      • allowing you to participate in any organizations or events that you sign up for;
      • allow you to liaise with other users of the Services, including other Participants and Event Managers

    • When participating in an event, any event manager or supervisor will see your personal data and other event participants may see your personal data.  
    • Research, develop, manage, protect and improve those services;
    • Advise you about any updates or changes to the services that may be of interest to you; and
    • Develop and maintain our relationship with you and communicate with you

In addition, from time to time, we may use your personal information for the following purposes:

    • to detect and protect InitLive and third parties against error, fraud, theft and other illegal activity, and to audit compliance with InitLive’s policies and contractual obligations;
    • to understand your needs and preferences, including to contact and communicate with you and to conduct surveys, research and evaluations;
    • to analyze, aggregate and prepare reports and recommendations based on data you provide to us through your use of the service or our Site;
    • for any other purpose that you may consent to from time to time.

4. LAWFUL BASIS FOR PROCESSING

We process your Personal Information in order to fulfil our contractual obligations to you under our terms of use, where we act as Data Controller, or to fulfil our contractual obligations to any contractor whom you correspond with through our Services, where we act as Data Processor.
 

5. WHEN WE DISCLOSE YOUR PERSONAL INFORMATION

InitLive may share personal information with third parties engaged to assist us in providing services (including but not limited to website development and hosting, data processing, credit card processing, marketing of our products and services, document management and office administration) to you or to carry out one or more of the purposes described above. In the event that we transfer your personal information to a third party for processing we will require the person or organization dealing with your personal information on our behalf  to protect your personal information in a manner consistent with this Privacy Policy or as otherwise required by law.

All third parties have their own very stringent privacy policies and have the necessary EU data transfer agreements in place.  Companies include AWS and Twilio.

These service providers are prohibited from using your personal information for any purpose other than to provide this assistance and are required to protect personal information disclosed by InitLive and to comply with the general privacy principles described in this Privacy Policy.

InitLive reserves the right to disclose personal information to a third party if a law, regulation, search warrant, subpoena or court order legally requires or authorizes us to do so.

InitLive also reserves the right to disclose and/or transfer personal information to a third party in the event of a proposed or actual purchase, sale (including a liquidation, realization, foreclosure or repossession), lease, merger, amalgamation or any other type of acquisition, disposal, transfer, conveyance or financing of all or any portion of InitLive or of any of the business or assets or shares of InitLive or a division thereof in order for you to continue to receive the same services from the third party.

Where we act as a Data Processor, the disclosure of your personal information will be the responsibility of the Data Controller.

6. KNOWLEDGE AND CONSENT

INITLIVE COLLECTS PERSONAL INFORMATION ABOUT YOU ONLY WHEN YOU VOLUNTARILY PROVIDE IT. Typically, we will seek consent for the use or disclosure of your personal information at the time of collection. In certain circumstances, consent may be sought after the information has been collected but before use (for example, when we want to use information for a purpose not previously identified).

The form of consent that we seek, including whether it is express or implied, will largely depend on the sensitivity of the personal information and the reasonable expectations of the individual in the circumstances.

You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. If you wish to withdraw your consent at any time, please contact our Privacy Officer at 613-271-5983 (ext. 1042) or privacy@InitLive.com. If you refuse or withdraw your consent, 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.

We will not, as a condition of the supply of a product or service, require you to consent to the collection, use or disclosure of information beyond that required to fulfill the explicitly specified and legitimate purposes for which the information is being provided.

7. USE OR DISCLOSURE FOR MARKETING, ADVERTISING AND SPONSORSHIP PURPOSES

We may also use (but will not disclose) your personal information to promote and market additional goods, services and special offers from us, our affiliates and sponsors, including by means of direct marketing. To ensure advertisers understand who our subscribers are and what they are interested in, we will compile your information and create general profiles of our subscribers’ demographic information and interests. However, we will never share any PERSONALLY IDENTIFIABLE information with our advertisers.

8. COOKIES

When you visit our Site, we place a text file called a “cookie” in the browser directory of your computer’s hard drive. A cookie is a small piece of information that a website can store on your web browser and later retrieve. The cookie cannot be read by any website other than the one that set up the cookies. Aggregate, but not individual, cookie and tracking information may be shared with third parties.

9. HOW WE PROTECT YOUR PERSONAL INFORMATION

InitLive makes all commercially reasonable efforts to ensure that personal information collected from you is protected against loss and unauthorized access. This protection applies in relation to information stored in both electronic and hard-copy form. Access to your personal information is restricted to selected employees or representatives. In addition, we employ robust information security techniques to protect personal information against loss and unauthorized access.

InitLive educates all its employees on the importance of privacy. It is InitLive’s policy to give access to personal information only to those employees who require it to carry out the responsibilities of their jobs or to other such third parties with similar designated responsibilities and who are subject to contractual confidentiality restrictions with InitLive.

10. LINKS TO THIRD-PARTY SITES

Our Site may offer links to other third-party websites for your convenience. You should be aware that operators of linked websites may also collect your personal information (including information generated through the use of cookies) when you link to their websites. InitLive is not responsible for how such third parties collect, use or disclose your personal information so it is important to familiarize yourself with their privacy policies, which may differ from ours, before providing them with your personal information. InitLive cannot be held liable for your use of such third-party websites.

11. RETENTION OF YOUR PERSONAL INFORMATION

We retain your personal information for as long as necessary to fulfill the purpose(s) for which it was collected and to comply with applicable laws. When that need has ended, your personal account information will be anonymized in order to keep the integrity of any event data.  

12. CONTROL OF YOUR PERSONAL INFORMATION

At InitLive, we want you to be able to maintain control over how we use your personal information. You will always have the option to instruct us not to use your name, e-mail, postal code, etc. beyond providing you with the service or information you requested. Additionally, e-mail communications will always include an identification of the sender. Should you wish to unsubscribe at any time, you may instruct us to immediately do so.

13. CHANGES TO OUR PRIVACY POLICY

InitLive reserves the right to modify this Privacy Policy at any time without notice. The Privacy Policy posted at any time or from time to time via this Site shall be deemed to be the Privacy Policy then in effect.

14. YOUR RIGHTS, ACCESS TO, CORRECTING OR UPDATING YOUR INFORMATION

If you request access to your personal information, subject to certain exceptions, InitLive will inform you of the existence, use and disclosure of your personal information and will provide you with a summary of that information. If InitLive determines not to provide you access to your personal information, we will provide an explanation. In certain circumstances, you also may have the right:

  • To access and receive a copy of the Personal Data we hold about you
  • To rectify any Personal Data held about you that is inaccurate
  • To request the deletion of Personal Data held about you

You have the right to data portability for the information you provide to us. You can request to obtain a copy of your Personal Data in a commonly used electronic format so that you can manage and move it.

Please note that we may ask you to verify your identity before responding to such requests. Further, if we are acting solely as a Data Processor and not as a Data Controller for that information, we will refer your request to the Data Controller who will be responsible for responding to your request.

You can help us maintain the accuracy of your personal information by notifying us of any changes to this information. You may contact InitLive in any one of the following ways to request access to or correction or update of your personal information:

E-mail: privacy@initlive.com

Send Mail: 390 March Road, Suite 127, Ottawa, Ontario K2K 0G7

Telephone: 613-271-5983 (ext. 1042).
 

15. CONTACTING US

If you have any questions or requests about InitLive’s Privacy Policy or if you have reason to believe that InitLive may have failed to adhere to this Privacy Policy, you may contact us at privacy@initlive.com or call us at 613-271-5983 (ext. 1042).

This Privacy Policy is intended to comply with the provisions of the Personal Information Protection and Electronic Documents Act (Canada) and GDPR.