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.
Please read on for more details.
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
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:
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:
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:
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
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:
We use your personal information to:
In addition, from time to time, we may use your personal information for the following purposes:
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.
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.
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.
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.
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.
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.
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.
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.
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:
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:
Send Mail: 390 March Road, Suite 127, Ottawa, Ontario K2K 0G7
Telephone: 613-271-5983 (ext. 1042).