Privacy Policy

January 2020

By using a website or digital workplace powered by IGLOO (which may be denoted by “IGLOO” in the page footer) or a service provided by IGLOO, you agree without limitation or qualification, to be bound by and to comply with this Privacy Policy.

IGLOO Inc. and its affiliates, and their successors and assigns (collectively referred to as “IGLOO”), are committed to protecting your privacy. This Privacy Policy applies to the collection, use and disclosure by IGLOO of information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular identified or identifiable individual or household (“Personal Information”) collected through IGLOO websites, including www.mygiordana.com and customercare.igloosoftware.com, and in connection with IGLOO services. Personal Information does not include information that has been anonymized or aggregated so that it can no longer be used to identify a specific individual.

About IGLOO

IGLOO has undertaken to build, manage, support and deliver a technology platform for the creation of “digital workplaces” — online networks for knowledge exchange and collaboration. Digital workplaces powered by IGLOO technology are general audience web sites and can be public, private or semi-private. Personal Information of users of digital workplaces, www.mygiordana.com or customercare.igloosoftware.com (collectively, “IGLOO Sites”) and related services provided by IGLOO (“IGLOO Services”) is collected, used and disclosed as described in this Privacy Policy. IGLOO does not intentionally collect information from persons under the age of 13.

Collection of Your Personal Information

If you are a business contact of IGLOO or a user of IGLOO Sites or IGLOO Services, then IGLOO may collect the following categories of Personal Information from you:

  • identifier information (e.g., name, email address, telephone number(s), mailing address, postal code, IP address, URL);
  • commercial information (e.g., products or services purchased or considered);
  • internet activity information (e.g., browsing history, search history)
  • professional or employment-related information (e.g., employer, role, tenure, reporting relationships);
  • education information; and
  • inferences drawn from any of the foregoing.

If you choose to sign up for certain of our services, we may collect additional Personal Information in order to create a billing account.

If you are a user of an IGLOO digital workplace, then in addition to the categories of Personal Information listed above, you can choose to create a public profile for your digital workplace usage, containing information about yourself, such as your hobbies, expertise, associations and interests. Any information you choose to enter in your public profile will be visible to other users of the network you are a member of in accordance with the privacy settings of your profile (as described below) and when you interact with other users (for example through blogs, forums, and chat rooms), a link to your public profile will be displayed in the member directory. To edit your personal information, log into your IGLOO community, click on your name to access your account and click “Edit Profile”. This will take you to your profile details pages. Click on the links and add/edit your personal information. Once you have completed or updated your personal profile, click the “Privacy” link and select the information you want to share with Nobody, Contacts, Members or Everybody (public).

Rights to Your Personal Information — California Residents

Effective January 1, 2020, The California Consumer Privacy Act provides that, if you are a resident of the State of California, you have the following rights in respect of your Personal Information:

  1. You have the right to request that IGLOO disclose the categories and specific pieces of Personal Information that IGLOO has collected about you, as well as the sources from which that Personal Information has been collected, IGLOO’s purpose of such collection, and the categories of third parties with whom that Personal Information is shared by IGLOO.
  2. You have the right to request that IGLOO disclose the categories of Personal Information collected by IGLOO and disclosed by IGLOO to third parties for a business purpose, as well as the categories of such third parties.
  3. Were IGLOO to sell your Personal Information (which it does not), you would have the right to request the categories of Personal Information sold in the last twelve months and the categories of third parties to whom it had been sold. You would also have the right to direct IGLOO not to sell your Personal Information.
  4. You have the right to request that IGLOO delete the Personal Information that it has collected about you.
  5. You have the right to request that IGLOO provide you with access to the Personal Information that it has collected about you.
  6. You have the right not to be discriminated against by IGLOO for exercising any of these rights.

You can exercise these rights by contacting IGLOO at [email protected] or 1-877-664-4566.

Use of Your Personal Information

IGLOO uses your Personal Information to operate IGLOO and deliver our services. If you are a business contact of IGLOO, these services may include the display of customized content and advertising based upon the information IGLOO has collected. IGLOO may use your Personal Information to inform you of other products or services available through our IGLOO technology and may use your Personal Information to send you surveys regarding current services, new services that we are considering offering and events that IGLOO is hosting. If you are not a business contact of IGLOO but strictly a user of an IGLOO digital workplace, IGLOO uses your Personal Information solely to facilitate your access to and use of that IGLOO digital workplace and related IGLOO Services.

Disclosure/Transfer of Your Personal Information

IGLOO does not sell, rent or lease your Personal Information to third parties. If you have consented to us doing so, IGLOO may, from time to time, contact you on behalf of a third party about a particular offering or materials that we believe may be of interest to you. In those cases, your Personal Information is not transferred to the third party.

IGLOO does disclose your Personal Information to third parties in order that those third parties (“Service Providers”) are able to provide services necessary to satisfy certain of IGLOO’s business purposes, such as handling the processing and delivery of mailings, processing transactions, providing security functions or customer support for digital workplaces, or performing statistical analyses of our digital workplace services (collectively, the “Third Party Services”).?The categories of Personal Information disclosed by IGLOO to Service Providers are the following:

  • identifier information (e.g., name, email address, telephone number(s), mailing address, postal code, IP address, URL);
  • commercial information (e.g., products or services purchased or considered);
  • internet activity information (e.g., browsing history, search history)
  • professional or employment-related information (e.g., employer, role, tenure, reporting relationships);
  • education information; and
  • inferences drawn from any of the foregoing.

We only permit Service Providers access to Personal Information to the extent that it is required to deliver the Third Party Services and we require all Service Providers, through written contractual provisions, to maintain the confidentiality of your information and respect your privacy. Specifically, we require Service Providers to establish and maintain appropriate safeguards for Personal Information and prohibit them from using Personal Information we transfer to them, except for the purpose of providing the Third Party Services, and from disclosing such Personal Information.

IGLOO may access and/or disclose your Personal Information if required or permitted to do so by law. IGLOO may also access and/or disclose your Personal Information under the following circumstances:

  1. to comply with a legal requirement including but not limited to one imposed by a warrant, subpoena, court order or like instrument served on IGLOO;
  2. where IGLOO has reasonable grounds to believe that such access or disclosure is necessary to prevent or investigate any breach of an agreement or contravention of a law; or
  3. in urgent circumstances to protect the life, health or security of any person.

IGLOO may also disclose your Personal Information to its successor or any assignee of IGLOO.

IGLOO does not use or disclose sensitive Personal Information, such as race, religion, or political affiliations, without your explicit consent. Any use or disclosure of your Personal Information within IGLOO will remain subject to the limitations of this Privacy Policy. IGLOO will give you notice and obtain your consent before using or disclosing your Personal Information for any purpose that is not described in this Policy.

Control of your Personal Information

In certain instances, IGLOO offers its users an opportunity to limit the collection, use and sharing of their Personal Information. For example, you may choose not to receive marketing materials from IGLOO, on its own behalf or that of third parties, and may stop the delivery of future promotional e-mail and Newsletters. When providing Personal Information to IGLOO or responding to a communication from IGLOO, look for a button, box, a question asking whether or not you want to provide or share your Personal Information, or an unsubscribe option.

There is some information which IGLOO must collect to provide you with services and some communications that you will not be able to unsubscribe from, as they are considered an integral part of the service you have chosen. If you do not wish to provide such information, you may not be able to access certain IGLOO Sites and IGLOO Services.

IGLOO respects your right to access, correct, request deletion of, or request restrictions on IGLOO’s use of your Personal Information as required by applicable law.

To the extent required by applicable law,

  • you have the right to know what Personal Information we maintain about you;
  • if we do have your Personal Information, we will provide you with a copy;
  • if your information is incorrect or incomplete, you have the right to ask us to update or correct such information;
  • you have the right to object to our processing of your Personal Information; and
  • you may also ask us to delete or restrict your Personal Information.

IGLOO will honour any right under applicable law that you might have to access, modify or erase your Personal Information. To request access and to find out whether any fees may apply, if permitted by applicable national laws, please contact our Privacy Officer as indicated below. Where you have a statutory right to request access or request the modification or erasure of your Personal Information, IGLOO can still withhold that access or decline to modify or erase your Personal Information where permitted or required in accordance with applicable national laws, but we will give our reasons if we have such a retention requirement.

Customer Data

IGLOO’s customers and their personnel (“Named Users”) may electronically submit data or information to IGLOO Sites and IGLOO Services for hosting and processing purposes (“Customer Data”). IGLOO will not review, share, distribute, or reference any such Customer Data except as provided in the Master Terms of Service Agreement entered into between IGLOO and its customer or as may be required by law. If you are a Named User whose Personal Information has been collected in accordance with a Customer’s use of IGLOO Sites and IGLOO Services and you wish to exercise any rights you may have to access, correct, amend or delete such Customer Data, please inquire with our customer directly. Because IGLOO personnel may have limited ability to access Customer Data, if you wish to make your request directly to IGLOO, please provide the name of IGLOO’s customer who submitted your data to an IGLOO Site or IGLOO Service. We will generally refer your request to that customer and will support them as needed in responding to your request within a reasonable timeframe.

Security of your Personal Information

IGLOO is committed to protecting the security of your Personal Information. We use a variety of security technologies and procedures to help protect your Personal Information from unauthorized access, use, or disclosure. For example, we store the Personal Information you provide on computer systems with limited access, which are located in controlled facilities. IGLOO Sites and IGLOO Services are hosted in Canada and the United States of America and your Personal Information will be stored in one of these countries. When we transmit highly confidential information (such as a credit card number) over the Internet, we protect it through the use of encryption technologies, such as the Secure Socket Layer (SSL) protocol.

Use of Cookies

IGLOO uses “cookies” to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.

One of the primary purposes of cookies is to provide a convenience feature to save you time. For example, if you personalize IGLOO pages, or register with an IGLOO Site or subscribe to IGLOO Services, a cookie helps to recall your specific information on subsequent visits. This simplifies the process of recording your Personal Information, such as billing address, preferred e-mail address, and so on. When you return to IGLOO, the information you previously provided can be retrieved, so you can easily use the IGLOO features that you customized.

You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. Please note that if you choose to decline cookies, you may not be able to fully experience the interactive features of the IGLOO Sites or IGLOO Services.

Changes to this Policy

IGLOO may update or revise this Privacy Policy at any time. Accordingly, IGLOO encourages you to periodically review this Privacy Policy as your continued use of IGLOO Sites or IGLOO Services represents your agreement with the then-current Privacy Policy. The date that this Policy was last updated will appear at the top of the Policy.

Enforcement of this Privacy Policy

IGLOO welcomes your comments regarding this Privacy Policy. If you believe that IGLOO has not adhered to this Policy, would like to access or request an amendment to your Personal Information being held by IGLOO, please contact our Privacy Officer by telephone, e-mail, or postal mail using the contact information provided.

Privacy Officer

Igloo?Inc.
55?King?Street West
Kitchener, Ontario, N2G 4W1
Canada

E-mail: [email protected]