This policy takes effect on 1 July 2018.
Last Updated Date
This policy was last updated on 1 July 2018.
We take the security and privacy of you and your Personal Information very seriously and we are committed to safeguarding your privacy. Please be aware that communications over the Internet, such as emails, are not secure unless they are encrypted. We do not accept any responsibility for any unauthorized access, theft or loss of Personal Information beyond our reasonable control. We may change this policy without notice from time to time to reflect changes in legal or regulatory obligations; however, if we make any material changes we will notify you by email (sent to the email address specified in your account) or by means of a notice on our Sites prior to the change becoming effective. You may wish to check this section from time to time, because by visiting our Sites, you agree to accept any such changes.
The following words and expressions have the following meanings unless inconsistent with the context:
means any media that can be rendered on a web page intended for consumption by an end-user, including, but not limited to articles, quizzes, polls, surveys, videos, pictures, audio and embeds;
"Cookies" or "Localstorage"
a small amount of data sent from the server which is then stored on your computer's internal storage;
The Ontario Freedom of Information and Protection of Privacy Act, R.S.O. 1990, c. F.31 defines "Personal Information" to mean recorded information about any identifiable individual, including his or her name, address, telephone number, email address, age, gender, marital status, personal views, preferences and opinions;
Personal Information Protection and Electronic Documents Act, SC 2000, c. 5 (Canada), as amended from time to time;
General Data Protection Regulation, (EU) 2016/679, as amended from time to time;
"we", "us" or "our"
Icarus Partners, Inc., a company duly incorporated under the laws of the province of Ontario;
an individual, company or firm accessing our Site.
3. What We Collect
We may collect the following Personal Information:
- login information you provide to us upon registration with our Site, including your username, email address and password;
- Personal Information you provide to us following registration with our Site, including your date of birth and geographic location;
- when you contact us via email, mail or telephone we may collect Personal Information from you;
- Personal Information may also be obtained automatically by your internet browser settings;
- demographic information such as IP address, preferences and interests will be collected by analytics software installed on our Site; and,
- Personal Information collected where you complete our surveys and/or respond to our offers.
When you access our Sites, we automatically collect information on the type of device, browser and operating system version you use.
We do not ask you for, access or track any location based information from your mobile device at any time while using our Sites.
4. What We Do With The Information We Gather
We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:
- optimization of the user interface and user experience;
- internal record keeping;
- we can deal with any general queries you raise from time to time by mail, by email or by telephone;
- we may use the information to improve our products and services;
- we may periodically send promotional emails containing information which we think you may find interesting using the email address which you have provided;
- for security purposes to protect your Personal Information held and/or processed by us;
- for training our employees in respect of providing our services to you;
- for our general marketing purposes unless you have notified us to the contrary;
- to prevent, investigate or prosecute activity we think may be potentially illegal, unlawful or harmful; and,
5. Who Else Gets To See Your Personal Information
Third parties engaged to assist us in providing services to you.
We may share Personal Information with third parties engaged to assist us in providing services to you or to carry out one or more of the purposes described in Section 4. 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 collected by them on our behalf or disclosed to them by us and to comply with the general privacy principles described in this policy.
Such marketing companies used by us from time to time.
We may share Personal Information with marketing companies engaged to assist us in promoting our services to you or to carry out one or more of the purposes described in Section 4. These marketing companies are prohibited from using your Personal Information for any purpose other than to provide this service and are required to protect Personal Information collected by them on our behalf or disclosed to them by us and to comply with the general privacy principles described in this policy.
If a law, regulation, search warrant, subpoena or court order legally requires or authorizes us to do so.
We reserve 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 and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
In the event of a proposed or actual acquisition.
We reserve 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 Icarus Partners, Inc. or of any of the business or assets or shares of Icarus Partners, Inc. or a division thereof in order for you to continue to receive the same products and services from the third party. In any of these events, you will be notified via email and/or a prominent notice on our Site of any change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information.
6. Security, Retention and Storage of Personal Information
We are committed to ensuring that your Personal Information is secure. In order to prevent loss, theft and unauthorized access, copying, use, modification or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and help secure the Personal Information we collect. All of our employees and subcontractors with access to your Personal Information and/or who are associated with the processing of that data are contractually obliged to respect the confidentiality of your Personal Information. Our safeguards include firewalls, encryption technology, password protected computers and detailed contracts with our employees and contractors.
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, and your consent to such purposes(s) remains valid after termination of our relationship with you.
For the purposes set out in this policy, we or one of our affiliates or an unaffiliated service provider may process and store your Personal Information outside of the jurisdiction in which you reside, and under the laws of those other foreign jurisdictions, in certain circumstances courts, law enforcement agencies, regulatory agencies or security authorities in those other foreign jurisdictions may be entitled to access your Personal Information. By providing us with your Personal Information, you are allowing your Personal Information to be transferred outside of Canada. For more information about our policies and practices related to the use of foreign service providers, please contact our Privacy Officer using a method described in Section 11, Contact Us.
For the purposes of the GDPR, if you are accessing our Sites from within the European Economic Area ("EEA") and/or you are a citizen of the European Union ("EU"), please be aware that Icarus Partners, Inc. is a Canadian company, with its offices in Toronto, Ontario. Please also be aware that data centres hosting our cloud-based computing infrastructure may be located in the United States.
The European Commission has made an "adequacy decision" with respect to the data protection laws of both Canada and the United States.
7. Cookies and/or Local Storage
- make our Sites work as you would expect;
- save you having to login every time you visit our Sites;
- remember your settings during and between visits;
- offer you free services/content (thanks to advertising);
- personalize our Sites to you to help you get what you need faster; and,
- collect any Personal Information (without your express permission);
- collect any sensitive information (without your express permission); and,
- share Personal Information to third parties (except as otherwise set out in this policy).
At this time, there is no way to prevent Google Analytics or New Relic Cookies being set other than to disable Cookies in your browser, or not use our Sites. If you have disabled Cookies in your browser, you will be denied access to the portions of our Sites that legitimately require Cookies for functionality.
8. Advertising Cookies
A special note on advertising Cookies:
Cookies are widely used in online advertising. We only work with advertising partners who work to accepted privacy standards such as those set by the Digital Advertising Alliance of Canada (DAAC), which can be found at http://www.youradchoices.ca.
You can opt-out of advertising Cookies with a browser plug-in or browser settings or through services provided by the National Advertising Initiative or the Digital Advertising Alliance.
https://support.apple.com/kb/PH21411 (Safari); and
If you use your browser settings to block all Cookies, you may not be able to access all or parts of our Sites. Please visit your browser's help and support website for more information.
Our third party advertising partners may employ clear gifs, images, and scripts that help them better manage content on our Sites. We do not tie the information gathered to your Personal Information.
9. Links to Other Websites
10. Controlling Your Personal Information
You may choose to restrict the collection, use or disclosure of your Personal Information in the following ways:
When you leave comments on our Sites, you should be aware that any information you provide may be read, collected, and used by others who access them. You can remove any of your previously submitted information, by availing yourself to the delete option or by contacting us using a method described in Section 11, Contact Us. In some cases, we may not be able to remove your Personal Information, in which case we will let you know if we are unable to do so and why.
If you have previously agreed to us using your Personal Information, you may change your mind at any time by contacting us using a method described in Section 11, Contact Us.
If you wish to subscribe to our newsletter(s), we will use your name and email address to send the newsletter to you. Out of respect for your privacy, you may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in those emails or by contacting us using a method described in Section 11, Contact Us.
You have the right to request from us information as to what Personal Information which we are processing about you under PIPEDA and other applicable privacy laws. Unless prohibited by law, a small fee of $10.00 CAD will be payable as such requests will only be answered by registered post to ensure the privacy of the recipient. If you would like a copy of the relevant information please write to the Privacy Officer, which should be accompanied by the $10.00 fee (if applicable). We will provide you with the relevant information within thirty (30) days of receipt of the fee or otherwise as required by law.
11. Contact Us
If you have any queries about our processing or use of your Personal Information, or wish to modify or correct or delete your Personal Information, you should write, in the first instance to our Privacy Officer.
12. Privacy Commissioner of Canada
If you want to learn more about your rights regarding your Personal Information, you should contact the Office of the Privacy Commissioner of Canada at 1-800-282-1376 or visit their website at http://www.priv.gc.ca/index_e.asp.