- What information we collect and why we collect it.
- How we use that information and when we disclose it.
- How to access and update your personal information.
Your privacy matters to us so please take the time to familiarize yourself with our policies, and if you have any questions please contact us at firstname.lastname@example.org.
1. IMPORTANT INFORMATION AND WHO WE ARE
Please note that neither the Website nor the Service is intended for children under 16 years of age. No one under age 16 may provide any information to or on this Website or through our Services. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website or on or through any of its features, use any of the interactive or public comment features of this Website or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us.
Our full details are:
Email address: email@example.com
Privacy Officer, Debacle Inc.
1 Yonge Street, Suite 1801
Toronto ON M5E 1W7
If you are based in the European Union, you also have the right to make a complaint at any time to your local supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the regulator so please contact us at firstname.lastname@example.org in the first instance.
This version was last updated October 23, 2018.
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.
This Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share information about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy notice of every website you visit.
2. THE INFORMATION WE COLLECT ABOUT YOU
Personal data, or personal information, means any information relating to an identifiable person who can be directly or indirectly identified. It does not include data which cannot be related to an identifiable person (anonymous data).
We may collect, use, store and transfer different kinds of personal information about you which we have grouped together follows:
- Identity Data includes first name, last name, username or similar identifier.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes payment card details.
- Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
- Technical Data includes internet protocol (IP) address, your mobile device’s unique ID number, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Website.
- Profile Data includes your username and password, purchases or orders made by you, your location, preferences, feedback and survey responses.
- Usage Data includes information about how you use our Website, app(s) and Services, such as the buttons, controls, products and ads you click on, pages of our application or Website that you visit, the time spent on those pages, your search queries, the dates and times of your visits, but also about the webpage you were visiting before you came to our Website app(s) and the webpage, app(s) you go to next
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Recording Data includes any personal information that may be included in any recordings that you submit through the service.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. While you may include such information in your recordings, we do not intentionally store, access or classify any such information and you are solely responsible for the inclusion of any such information. We encourage you not to include any unnecessary personal information, including in particular any Special Categories of Personal Information, in any recordings that you submit through the Services.
If you fail to provide personal information
Where we need to collect personal information by law, or under the terms of a contract we have with you and you fail to provide that information when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
3. HOW IS YOUR PERSONAL INFORMATION COLLECTED
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you :
- sign up for a demo of our services;
- create an account and profile with us;
- purchase one of services;
- subscribe to our email alerts;
- complete one of our online forms to receive our reports and case studies;
- download or otherwise access one of our e-books, magazines, videos;
- contact our customer service;
- request marketing to be sent to you; or
- give us some feedback.
Third parties or publicly available sources. We may receive personal information about you from various third parties and public sources as set out below :
Technical Data from the following parties:
- analytics providers such as Google Analytics based outside the EU;
- search information providers such as Google based inside or outside the EU.
Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Stripe based outside the EU.
Identity and Contact Data from our partners, data brokers or aggregators based inside or outside the EU.
Identity and Contact Data from publicly available sources such as LinkedIn, Instagram, and other social networking sites based outside the EU.
Recording Data is only collected by us where you submit recordings to us through the Service. We do not collect Recording Data from any other source.
4. HOW WE USE YOUR PERSONAL INFORMATION
We will only use your personal information when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
The the types of lawful basis that we will rely on to process your personal data are:
Legitimate Interest - this means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract – this means processing your information where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation - this means processing your personal information where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Generally we do not rely on consent as a legal basis for processing your personal information other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal information
We have set out below, in a table format, a description of all the ways we plan to use your personal information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your information. Please contact us if you need details about the specific legal ground we are relying on to process your personal information where more than one ground has been set out in the table below.
|Purpose/Activity||Type of Data||Lawful basis for processing including
basis of legitimate interest
|To register you as a new customer||
||Performance of a contract with you|
|To allow your use of the Service to record, upload and distribute your recordings||
||Performance of a contract with you|
|To process and deliver your order including:
|To manage our relationship with you which will include:
|To enable you to partake in a prize draw, competition or complete a survey||
|To administer and protect our business and this Website and Mobile App (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||
||Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, services, marketing, customer relationships and experiences||
||Necessary for our legitimate interests (to define types of customers for our services, to keep our Website and Mobile App updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about services that may be of interest to you||
||Necessary for our legitimate interests (to develop our services and grow our business)|
Recordings: In order to make a sound recording, you must grant the Service access to your microphone. If you create a sound recording, we will collect and store such sound recording. You may invite others to record a sound recording with you by sending an invitation link through the Service. If your email address is linked with a profile photo of you, then your photo and username will be visible to individuals whom you invite to record sound recordings with you through the Service. If you want to invite others to record with you, you will be asked to provide us with their email addresses and the invited individuals will be asked to provide their screen names. If such individuals have profile photos attached to their email addresses, then we will also collect their photo. We store personal information collected about contributors of sound recordings in the applicable session.
Sharing Features: If you use any third-party platforms that we support such as Facebook or Twitter to share content such as sound recordings, such content will be publicly available and searchable on the Internet.
Messages: Users have the ability to send instant messages to each other while recording podcasts through the Services. If you send a message to another user, they will be able to see your username, profile photo and the content of your message.
Referrals: If you want to invite a friend to join our Service, you may do so by providing us with their name and email address. We will use this information to send your friend one email inviting them to join our Service. If they do not set up an account to use our Service, we will delete their contact information.
We strive to provide you with choices regarding certain personal information uses, particularly around marketing and advertising. You may elect to opt out of receiving any further marketing or advertising emails from us through the mechanism provided in those emails.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you. You will receive marketing communications from us if you have requested information from us or purchased services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal information with any company outside our company for marketing purposes, including service providers who perform marketing services on our behalf, such as conducting surveys, sending communications to you on our behalf, or serving advertisements to you.
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal information provided to us as a result of a service purchase, service experience or other transactions.
Change of purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at email@example.com.
If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL INFORMATION
We may have to share your personal information with the parties set out below for the purposes set out in the table in paragraph 4 above.
- Third Party categories as set out below:
- Service providers who provide IT and system administration services.
- Social networking sites to which you have linked your account.
- Professional advisers including lawyers, bankers, auditors and insurers based in Canada and the United States who provide consultancy, banking, legal, insurance and accounting services.
- Regulators and other government authorities [acting as processors or joint controllers] based in Canada, the United States and in the EEA who require reporting of processing activities in certain circumstances.
We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.
6. INTERNATIONAL TRANSFERS
We share your personal information within our company. This will involve, if you are based in the European Union, transferring your data outside the European Economic Area (EEA).
Many of our external third parties are also based outside the European Economic Area (EEA) so their processing of your personal information will involve a transfer of data outside the EEA.
If you are based in the European Union, whenever we transfer your personal information out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring appropriate safeguards are implemented.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. DATA RETENTION
How long will you use my personal information for?
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax and other legally required purposes.
In some circumstances you can ask us to delete your information: see Request erasure below for further information.
In some circumstances we may anonymize your personal information (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal information. You have the right to:
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information in the following scenarios: (a) if you want us to establish the information’s accuracy; (b) where our use of the information is unlawful but you do not want us to erase it; (c) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal information to you or to a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. Withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us using the details set out above.
No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Effective date: October 23, 2018