Effective date: January 4, 2018
A. WHAT INFORMATION CRAWFORD COMPLIANCE COLLECTS FROM YOU
Crawford Compliance collects only the information required to provide products and services to you. The amount of information provided by you and collected by Crawford Compliance depends on the circumstances. Crawford Compliance may collect two types of information about you: Personal and Non-Personal.
“Personal Information”. Personal Information refers to any information about an identifiable individual (e.g. name, mailing address, telephone number or e-mail address), or an individual whose identity may be inferred or determined from the information. Crawford Compliance may collect Personal Information when you use the Crawford Compliance Properties including, without limitation, setting up account information, inputting data using the Crawford Compliance Software, GPS tracking data gathered through the Crawford Compliance Services and the Crawford Compliance Software, corresponding with Crawford Compliance, or otherwise volunteering information about yourself.
“Non-Personal Information”. Non-Personal Information refers to information that, by itself, does not identify you as a specific individual (e.g. demographic information or website visitations). Crawford Compliance may collect Non-Personal Information through any of the methods discussed above as well as automatically through use of industry standard technologies described further below.
You acknowledge and agree that a fundamental aspect of the Crawford Compliance’s Services is the gathering and sharing of location and activity data where Users of our Services provide such information so that other authorized Users can monitor such information.
B. HOW CRAWFORD COMPLIANCE COLLECTS YOUR INFORMATION
Registration. Prior to using one or more of the Crawford Compliance Properties, Crawford Compliance may require you to provide us with certain Personal Information and Non-Personal Information to create an account (“Account”) or to enable features or functionality of the Crawford Compliance Properties.
For Users, Authorized Users and Contractors, Crawford Compliance may gather Personal Information about organizational representatives via various methods (such as by phone, email, location tracking and other data provided by phones, tablets, laptops and other mobile devices, online forms, in-person meetings) but only if such Personal Information is submitted voluntarily. Use of the Crawford Compliance Services constitutes authorization of the gathering and sharing of such Personal Information. Crawford Compliance may use such Personal Information for providing the Crawford Compliance Services, sales, marketing, and support of the Crawford Compliance Properties. This Personal Information is never shared with third parties other than (i) providers of Third Party Services utilized by Authorized Users and Contractors in connection with Crawford Compliance Services and (ii) as authorized by a User, an Authorized User or Contractor pursuant to their use of the Crawford Compliance Services.
User communications. When you send email or other communications to Us, We may retain those communications in order to process your inquiries, respond to your requests and improve the Crawford Compliance Properties.
Payment Information. When creating an Account, for certain Crawford Compliance Properties, or when you make online purchases, you may be asked to provide information, which may include your payment instrument number (e.g., credit card), your name and billing address, and the security code associated with your payment instrument (e.g., the CVV) and other financial data (“Payment Information”). We use Payment Information to complete transactions, as well as for the detection and prevention of fraud. When you provide Payment Information while authenticated, we will store that data to help you complete future transactions without your having to provide the information again. We do not, however, retain the security code associated with your payment instrument (e.g., the CVV) in this manner. We also encrypt your credit card information. To remove or modify Payment Information, please contact us. After you close your account or remove Payment Information, however, we may retain your Payment Information for as long as reasonably necessary to complete your existing transactions and for the detection and prevention.
Information Collected Through Technology. Crawford Compliance automatically collects and receives certain information from your computer or mobile devices, including the activities you perform on the Crawford Compliance Site, the Crawford Compliance Software and the Crawford Compliance Services, the type of hardware and software you are using (for example, your operating system or browser), geographic location information and information obtained from cookies (see below). As noted above, given the nature of the Crawford Compliance Services, this information will be shared with Authorized Users in order to provide the tracking services provided by Crawford Compliance. If you have an Account, we may also link this Non-Personal Information to your Account to better understand your needs and the needs of Users in the aggregate, diagnose problems, analyze trends, provide services, improve the features and usability of the Crawford Compliance Properties, and better understand and market to our Authorized Users and Contractors and Users.
We use technology to automatically gather information by the following methods:
b. IP Address. You may visit many areas of the Crawford Compliance Site anonymously without the need to become a registered User. Even in such cases, Crawford Compliance may collect IP addresses automatically. An IP address is a number that is automatically assigned to your computer whenever you begin services with an Internet services provider. Each time you access the Crawford Compliance Site and each time you request one of the pages of the Crawford Compliance Site, the server logs your IP address.
c. Web Beacons. Web beacons are small pieces of data that are embedded in web pages and e-mails. Crawford Compliance may use these technical methods in HTML e-mails that Crawford Compliance sends to Users to determine whether they have opened those e-mails and/or clicked on links in those e-mails. The information from use of these technical methods may be collected in a form that is Personal Information.
d. API Collection. Information collected by the Crawford Compliance Site through APIs, including location information may be collected and used for other Crawford Compliance Services including generating emails providing tracking information.
Information You Provide About a Third Party. You may have the opportunity to communicate with others from the Crawford Compliance Properties. If you choose to take advantage of this functionality, we may ask you to provide us with certain information about the person with whom you wish to communicate (e.g., name, e-mail address, etc.). Crawford Compliance collects such information for the purposes of facilitating the requested communication, which may contain a specific message from you. Unless we explicitly say otherwise, Crawford Compliance will not use this information for other marketing purposes without first obtaining consent from the person to whom the relevant information pertains. Please be aware that when you use any invitation functionality on the Crawford Compliance Properties, your e-mail address, name or username, and message may be included in the communication sent to your addressee(s).
C. HOW CRAWFORD COMPLIANCE USES YOUR INFORMATION
Personal Information. Crawford Compliance identifies the purpose for which your Personal Information is collected and will be used or disclosed. If that purpose is not listed below, we will identify any additional purposes for which we will collect your Personal Information, before or at the time of collection, and we will obtain your consent to collect, use or disclose your Personal Information for such additional purpose(s).
By using the Crawford Compliance Properties, you will be deemed to consent to our use of your Personal Information for the purposes of:
location and timing, tracking and dissemination of information to employers and Authorized Users;
communicating with you generally;
processing your purchases;
processing and keeping track of transactions and reporting back to you;
protecting against fraud or error;
providing information or services requested by you;
administering and managing the Crawford Compliance Properties and our business operations;
personalizing your experience with the Crawford Compliance Site, as well as evaluating statistics on Crawford Compliance Site activity;
performing statistical analyses of your behavior and characteristics, in order to measure interest in and use of the various sections of the Crawford Compliance Site;
communicating with you on other websites;
delivery of content and information to providers of Third Party Services;
complying with legal and governmental requirements; and/or
fulfilling any other purpose that would be reasonably apparent to the average person at the time that we collect it.
Otherwise, we will obtain your express consent (by verbal, written or electronic agreement) to collect, use or disclose your Personal Information. You can change your consent preferences at any time by contacting us (see the “How to Access and Change Your Personal Information” section below).
Non-Personal Information. Crawford Compliance may use Non-Personal Information for the following purposes:
System Administration: Crawford Compliance may use Non-Personal Information for the purposes of system administration, assisting in diagnosing problems with Crawford Compliance servers, monitoring Crawford Compliance’s system performance and traffic on the Crawford Compliance Properties and to gather broad demographic information about Crawford Compliance customers.
D. HOW TO ACCESS AND CHANGE YOUR PERSONAL INFORMATION
Updating Your Personal Information. Upon request, Crawford Compliance shall allow Users to update or correct Personal Information previously submitted, but only to the extent such activities will not compromise privacy or security interests. Additionally, upon request, Crawford Compliance shall delete Personal Information from the database where such information is stored; however, it may be impossible to entirely delete a User’s entry without some residual information being retained due to the manner in which data backups are maintained. Requests to delete Personal Information may be submitted to email@example.com.
E-mail Preferences. Crawford Compliance may use your Personal Information to send you e-mails periodically listing promotions or events relating to the Crawford Compliance Properties or from Crawford Compliance’s marketing partners or sponsors. You have the choice to opt-out of receiving such promotional e-mails by sending an e-mail to firstname.lastname@example.org/or following the instructions in such correspondence. Once Crawford Compliance has processed your opt-out request, Crawford Compliance will not send you promotional e-mails unless you opt back in to receiving such communications.
E. DISCLOSURE OF INFORMATION TO THIRD PARTIES
Except as described below, we do not sell, transfer or otherwise disclose, sell, trade or otherwise transfer your Personal Information to outside parties. This statement does not include trusted third party service providers who assist us in administering and providing the Crawford Compliance Properties or provide services to us. Examples include storing and managed data, analyzing data, providing marketing assistance, integrations of Third Party Services, processing credit card payments and providing customer service. These third party service providers will have access to Personal Information needed to perform their functions, but may not use it for other purposes. We may use service providers located outside of Canada, and, if applicable, your Personal Information may be processed and stored in other countries and therefore may be subject to disclosure under the laws of those countries.
We may share Payment Information with third parties for purposes of fraud prevention or to process payment transactions. We may also release your information when we believe release is appropriate to comply with the law, enforce our policies, or protect our or others’ rights, property or for safety. We may also provide non-Personal Information to other parties for marketing, advertising or other uses.
Information, including Personal Information, which we collect from Users, is considered to be a business asset. As a result, in the unlikely event that we go out of business, enter bankruptcy or if we are acquired as a result of a transaction such as a merger, acquisition or asset sale, your Personal Information may be disclosed or transferred to the third-party acquirer in connection with the transaction.
Lastly, we may provide Authorized Users with certain identifiable information (including Personal Information) with respect to Contractors and other Users in connection with providing the Crawford Compliance Services. The use of such information will be subject to the information and privacy practices and policies of such Authorized Users and Crawford Compliance will not be responsible or liable or the use of any information by such Authorized Users. Crawford Compliance will not be responsible for their use of your information. Under certain exceptional circumstances, Crawford Compliance may have a legal duty or right to collect, use or disclose your Personal Information without your knowledge or consent. In accordance with applicable laws, we will not disclose any consumer information (which may include Personal Information) without your written consent, except where consumer information is required to be disclosed: (i) for billing or market operation purposes; (ii) for law enforcement purposes; or (iii) for the purpose of complying with a legal or regulatory requirement.
You are deemed to consent to disclosure of your information for the above purposes. If your Personal Information is shared with third parties other than Authorized Users, those third parties may be, but are not always, subject to appropriate agreements with Crawford Compliance and/or its Authorized Users to secure and protect the confidentiality of your Personal Information.
F. SAFEGUARDING YOUR PERSONAL INFORMATION
Crawford Compliance takes appropriate security measures, to protect against unauthorized access, alteration, disclosure or destruction of Personal Information. These include, but are not limited to, internal reviews of: (a) data collection; (b) storage and processing practices; (c) electronic security measures; and (d) physical security measures to guard against unauthorized access to systems where Crawford Compliance stores Personal Information.
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.
All Crawford Compliance employees, contractors and agents who access Personal Information are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, for unauthorized use or disclosure of Personal Information. Some or all of the Personal Information we collect may be stored or processed on servers located outside your jurisdiction of residence, whose data protection laws may differ from the jurisdiction in which you live. As a result, this information may be subject to access requests from governments, courts or law enforcement agencies in those jurisdictions according to laws in those jurisdictions.
G. THIRD PARTY WEBSITES AND SERVICES
The Crawford Compliance Properties may contain links to third party websites or services, including Third Party Services (collectively, “Third Party Sources”) who may collect Personal Information and Non-Personal Information directly from you. Links to Third Party Sources are intended for convenience only. Third Party Sources are wholly independent from Crawford Compliance. Third Party Sources may have separate privacy policies and data collection practices, independent of Crawford Compliance. Crawford Compliance: (a) has no responsibility or liability for these independent policies or actions; (b) is not responsible for the privacy practices or the content of such websites; and (c) does not make any warranties or representations about the contents, products or services offered on such websites or the security of any information you provide to them.
H. HOW TO CONTACT US
Email us: email@example.com.
Crawford Compliance Inc.
539 Riverbend Drive
Kitchener, ON N2K 3S3