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Effective Date: June 30, 2020

This Privacy Policy describes how VerticalScope Inc. and its subsidiaries and corporate affiliates (collectively, “VerticalScope”, “we”, “us” or “our”) collect information through our websites and mobile or other applications on which this Privacy Policy is posted (collectively, the “Sites”) and, subject to the privacy policies of those third party platforms, through our accounts on various third party social media platforms. This Privacy Policy also describes how we may use and share this information and how you can opt out of some of our uses and disclosures of your information.

Here are a few general principles to keep in mind as you read through this Privacy Policy:

  • Advertisements displayed to you on our Sites and elsewhere may be customized to your interests and preferences based on your personal information and usage information collected through our Sites, unless you opt out by following the instructions on the Digital Advertising Alliance of Canada Opt-Out Page, Your Online Choices from the European Interactive Digital Advertising Alliance, NAI Opt-Out Page and the Ad Choices Opt-Out Page. (You may have to opt out using each of your web browsing applications and devices separately.) However, if you opt out, we may still suggest offerings to you on our Sites based on your history at our Sites.
  • By visiting a Site or otherwise providing us with personal information, you agree that we may collect, use and share your personal information as described in this Privacy Policy. If you do not agree, please do not visit the Sites or provide us with any personal information.
  • As used in this Privacy Policy, “personal information” includes information that can be used to identify you as an individual or allow someone to contact you, as well as information attributed with such information.
  • We may at any time and at our sole discretion update this Privacy Policy by posting the updated Privacy Policy here along with the new effective date.

QUICK LINKS

Click on one of the links below to jump to the listed section:

  1. Information we collect
  2. How we use the information we collect
  3. Cookies, tracking technologies and interest-based advertising
  4. How we share your personal information
  5. How we store and protect your personal information
  6. Links to external content
  7. Children
  8. Accessing and correcting your personal information
  9. Users from the European Union
  10. California Privacy Rights
  11. Your choices
  12. How to contact us

1. Information we collect 

We collect different categories of personal information about you from different sources, including information you provide us directly, usage information about your visits to our Sites and information provided by third parties.

Information Provided By You or Third Parties 

We collect information you provide to us directly when you use our Sites. This includes:

  • Account Information: To create an account, we collect your username, email address and/or telephone number, and password. For some Sites you may be required to provide additional information such as your date of birth, gender, age or other personal information. We collect additional information that you choose to add to your account or public user profile, such as a profile picture or information about your hobbies, interests, activities or property (such as the type of vehicle you own). Your username is public, and other account information may be public depending on how your account profile is configured.
  • Transactional information: We may collect your name, contact information and payment card information when you purchase a product or service through our Site (such as a subscription or classified advertisement). Payments are processed by third-party payment processors (e.g., Stripe and Braintree), so please refer to the applicable processor’s terms and privacy policy for more information about how payment information is processed and stored.
  • Third Party Networks: If you use a third party network (including a social media account) to create an account on our Site, to log-in to our Site, or if you otherwise interact with a third party network through our Site (such as by using a plug-in), we will receive personal information from the third party network, such as your username, email address, gender, public profile information and any other information that you have agreed to share with us, whether explicitly or through your privacy settings. You should consult the respective privacy policies of these third party networks for information about their practices.
  • Content you submit: Our Site may offer public forums or communication platforms that allow you to communicate with other users, post information, content, images, photos or videos, post your opinions on surveys, or submit reviews or ratings (collectively, your “Content”). Your Content will be associated with your public user profile. Your Content and public user profile is public, unencrypted and non-confidential. This means that it can be read and used by others, including advertisers. We are not responsible for the information you choose to submit in these public areas. You should exercise caution when deciding to disclose personal information in public areas of our Site. We strongly recommend against sharing any personal sensitive information that could directly or indirectly be traced to any individual, including yourself.
  • Other information: We may collect personal information with your consent, where required or permitted by law, or when you choose to provide other information directly to us. For example, we may collect information when you fill out a form, participate in a survey, poll, contest or promotion, apply for a job, request customer support or otherwise communicate with us.

Information We Collect Automatically 

When you use or access our Sites, we may also automatically collect information about you. This includes:

  • Geographic Location: We collect geographical location information if the Site you are using is location-enabled and your device transmits location data and/or your IP address. This enables us to provide location-specific information to you.
  • Usage Data: We may log information when you access and use our Sites. This may include your IP address, user-agent string, browser type, operating system, referral URLs, device information (e.g., device IDs), pages visited, links clicked, the requested URL, hardware settings, and search terms. See Cookies, tracking technologies and interest-based advertising below.
  • Information collected from cookies and similar technologies: We, our service providers and third party advertising partners also collect information about users of the Sites automatically using cookies and other tracking technologies. See Cookies, tracking technologies and interest-based advertising below.

2. How we use the information we collect

We generally use the information we collect about you to operate, manage and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives, including:

  • to administer and manage our Site and provide our services, such as to create and administer accounts and facilitate the use and enjoyment of forums and communication platforms;
  • to enable geographic-specific features, such as geographic-specific information;
  • to provide the product, service, feature or information you have requested and to fulfill your transactions, including to process payments;
  • to send you administrative messages, updates, legal notices, technical notices or security alerts;
  • to customize your user experience and to personalize the services of VerticalScope and our ad partners and provide you with content of interest, including by tailoring the advertisements that are displayed to you to make them more useful and relevant to you;
  • to conduct research and development, analyze and understand trends and user behaviour and to improve our Sites, products and services;
  • to provide customer service, technical and other support;
  • to protect the safety of VerticalScope and our users, including to ensure compliance with our Terms of Use and other policies, block suspected spammers, address abuse, and detect and prevent fraud;
  • to provide you with newsletters, information, promotional offers and other advertising about us or our advertising partners;
  • to facilitate your participation in a contest or similar promotion, or a survey or poll;
  • to meet contractual obligations;
  • to facilitate corporate transactions;
  • to exercise our rights, defend legal claims and comply with law, legal process and internal policies; and
  • for other purposes with your consent or as permitted or required by law.

3. Cookies, tracking technologies and interest-based advertising

We, our service providers and third-party advertising partners use technologies that automatically collect information about Site visitors and their visits to the Sites, including as described below.

We automatically collect information about how you access, navigate and leave our Site, including the website you came from before visiting our Site, what browser type and operating system you are using, the internet protocol (IP) address you are accessing the Site from, your mobile device ID or Advertising ID if you visit our Site from a mobile device, the pages of our Site that you are navigating through, the date and time of your visit, how long you spend on our Site or certain pages of our Site, and what website you go to after visiting our Site. This information may be used to determine how many visitors visit our Site or certain areas of our Site, how long they remain on our Site, whether they use the hyperlinks we provide or respond to advertising and to tailor our advertisements to you. We may share this information with partners who referred you to our Site, and with advertising partners, who may use the information to optimize the traffic they send to us and for delivering targeted ads to you when you visit other websites.

We, our service providers and third-party advertising partners collect information about Site visitors using cookies and other tracking technologies (including browser cookies, pixels and Adobe Flash). We use these technologies to remember your preferences and facilitate your navigation of our Site. We and our service providers and third-party advertising partners also use these technologies to track your activities on our Site and other websites, including the websites and web pages that you visited, the ads or content that you clicked on, any items you may have purchased and the search terms you used, in order to deliver tailored advertising to you. We may also share a unique identifier linked to you (such as a hashed or encrypted version of your email address or telephone number) with advertising partners so that you may be served with tailored advertising on our websites or other third party websites. However, you may opt out of network advertising programs that track your activities across multiple websites to deliver personalized advertising content to you by visiting Digital Advertising Alliance of Canada Opt-Out Page, Your Online Choices from the European Interactive Digital Advertising Alliance, NAI Opt-Out Page and the Ad Choices Opt-Out Page.

If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject any cookies. You may also set your e-mail options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our e-mail and performed certain functions with it. See Your Choices below for information about your choices about how we use and share your information.

We use Google Analytics to help us understand how our Site visitors use the Site, and as well as certain features of Google Analytics Display Advertising to advertise online, sell advertising and to develop content. You can opt out of your usage data being included in our reports from Google Analytics and customize Google’s Display Network ads. Please visit Google’s Ad Settings and Google Analytics Opt-out Browser Add-on. Please visit How Google uses data when you use our partners' sites or apps for a description of how Google uses information sent by our browser and for ways you can control the information sent to Google.

Most modern web browsers provide the option to send a “do not track” signal to the websites you visit, indicating that you do not wish to be tracked. At this time, there is no generally accepted standard for how a website should respond to this signal, and we do not take any action in response to this signal. Our third party partners, such as web analytics companies and third party ad networks, collect information about your online activities over time and across the Sites and other online properties. These third parties may not change their tracking practices in response to “do not track” settings in your web browser and we do not obligate these parties to honor “do not track” settings.

4. How we share your information

We may share information we collect about you in the following circumstances.

Advertising partners

We share information with our third-party advertising partners as described in the Cookies, tracking technologies and interest-based advertising section above.

Service Providers

We may use service providers (including affiliates acting in this capacity) to provide services to us or to you on our behalf. For example, our service providers may host our Site, analyze data collected from our Site, provide customer service on our behalf, administer our promotions, facilitate and process transactions and payments, provide marketing or promotional assistance, distribute emails and other communications, post our advertisements (including online through targeted advertising campaigns), and collect your feedback on our Site and advertisements. We share your personal information with our service providers solely for the purposes of providing services to you and to us. They are not permitted to use your personal information for other purposes. Some of our service providers are located outside of Canada, including in the United States. While your personal information is located outside of Canada, it will be subject to legal requirements applicable to our service providers, for example, lawful requirements to disclose personal information to national security agencies or government authorities in certain circumstances. For EU residents, see Users from the European Union section below.

Aggregate or de-identified information

We may use your personal information to create aggregate statistics and de-identified data. We may use, share and sell this information for any purpose.

With your consent

We may share your personal information with third parties with your consent. For example, if you provide us with your contact information, such as an e-mail address, for the purposes of signing up for information, newsletters, contests, or marketing offers from a third party, or for receiving business offers or service quotes from a third party, we may share your personal information for that purpose. Once shared, your personal information will be subject to the privacy policy of that third party.

Business Transactions

We may disclose your personal information to third parties in connection with the proposed or actual financing, securitization, insuring, merger, sale, assignment or other disposal of all or part of VerticalScope or our business or assets. These third parties may use the information for the purposes of evaluating and/or completing the proposed transaction and thereafter as a successor of our interests.

Other

We may disclose your personal information in other circumstances where permitted or required by law or other legal process. For example, we may disclose your personal information: (a) to collect a debt owed to us; (b) as necessary to comply with a subpoena, warrant, court order or other legal process; (c) if disclosure is requested by an investigatory body, law enforcement official or governmental authority which has lawful authority to request the disclosure of the information in respect of an investigation or other legal process; or (d) if we have reasonable grounds to believe that the information relates to a breach of an agreement or contravention of a law, or to protect the personal safety of our users or defend our rights or property.

5. How we store and protect personal information

The security of your information is important to us. While we have implemented safeguards to protect the information we collect, no website or internet transmission is completely secure, and we cannot and do not guarantee the security of your personal information. We urge you to take steps to keep your personal information safe, such as choosing a strong password and keeping it private, as well as logging out of your user account, and closing your web browser when you have finished using a Site on a shared or unsecured device.

We maintain personal information on our servers (or those of our service providers). Certain accounts you create on our Sites are password protected. If you create an account on the Site, you are responsible for maintaining the strict confidentiality of your account password, and you shall be responsible for any activity that occurs using your account credentials, whether or not you authorized such activity. Please notify us of any unauthorized use of your password or account or any other breach of security. In identified parts of our Sites, we use SSL-encryption in an effort to protect data transmissions. Our policy is to limit access to sensitive personal information to employees, representatives and service providers who require access in connection with their job or service responsibilities.

If you correspond with us by email, text message, or using web forms like a “contact us” feature on the Sites, you should be aware that your transmission might not be secure or considered confidential. A third party could view the information you send in transit by such means or we could disclose the information you send in accordance with this Privacy Policy. We will have no liability for disclosure of your information, including due to errors or unauthorized acts of third parties during or after transmission.

6. Links to external content

Our Site may link or direct you to other websites, services or external content provided by third parties.  We do not exercise any control over these third party websites or services. We are not responsible for the privacy practices of such third party websites or services.  We recommend that you read the privacy policy for any third party website that you visit or service that you use.

7. Children

Our Sites are not directed to and we do not knowingly request or collect personal information from children - persons under 13 years of age, or another age if required by applicable law - without prior verifiable parental consent. If we become aware that we have unknowingly collected personal information about a child without verifiable parental consent, we will delete this information from our records or, if that is not reasonable, we will take reasonable available steps to de-identify the information.

8. Accessing or correcting your personal information

We encourage you to keep your personal information accurate and up to date. If you have an account with us, you can access and correct certain of the information in your account or public user profile by logging in to your account or profile and making the necessary edits.

You may request access to or correction of your personal information in our custody or control by contacting us as set out below. We may take reasonable steps to authenticate your identity before providing you with access to your personal information or making corrections. Please also note that in some cases we may not be able to provide you with the personal information you have requested (for example, if the information is subject to solicitor-client privilege or contains personal information of others that cannot be severed).

9. Users from the European Union

This section of the Privacy Policy applies only if you use the Site from a country that is a Member State of the European Union, and supplements the information in this Privacy Policy.

VerticalScope is the data controller for processing of information defined as personal data under the General Data Protection Regulation (“Personal Data”). VerticalScope participates in the IAB Europe Transparency & Consent Framework (“TCF”) and complies with its Specifications and Policies. VerticalScope uses the Consent Management Platform with the identification number CMP ID 10.

Retention

Your personal information will be retained for as long as reasonably necessary for the purposes set out above, considering criteria such as applicable rules on statute of limitations, legal requirements and the duration of your use of our Site and receipt of our services.

Legal Basis for Data Processing

We process Personal Data for the purposes set out in this Privacy Policy, as described above. Our legal basis to process Personal Data includes processing that is: necessary for the performance of the contract between you and VerticalScope (for example, to provide you with the services you request and to process payments); necessary to comply with legal requirements (for example, to comply with applicable accounting rules and to make mandatory disclosures to law enforcement); necessary for our legitimate interests (for example, to manage our relationship with you and to improve the Site and our services); and based on your consent (for example, to communicate with you about our products and services and provide you with marketing information), which may subsequently be withdrawn at any time (by emailing [email protected]) without affecting the lawfulness of processing based on consent before its withdrawal.

In some instances, you may be required to provide us with Personal Data for processing as described above, in order for us to be able to provide you all of our services, and for you to use all the features of our website.

International Transfers of Personal Data

Our personnel and some of the third-parties to whom we disclose Personal Data (as set out above) may be located in countries outside of the European Economic Area (“EEA”), including in countries that may not provide the same level of data protection as your home country. We take appropriate steps to ensure that recipients of your Personal Data are bound to duties of confidentiality and, where required under law, we implement measures such as standard data protection contractual clauses to ensure that any transferred Personal Data remains protected and secure. A copy of these clauses can be obtained by emailing [email protected]

Your Rights

You may be entitled, in accordance with applicable law, to object to or request the restriction of processing of your Personal Data, and to request access to, rectification, erasure and portability of your own Personal Data.  Requests should be submitted by contacting us by emailing [email protected]

If you are aware of changes or inaccuracies in your information, you should inform us of such changes so that our records may be updated or corrected. You may lodge a complaint with a supervisory authority, in particular in the EU Member State of your habitual residence, if you consider that our processing of your Personal Data infringes applicable law.

10. California Privacy Rights

This section is provided pursuant to the California Consumer Privacy Act of 2018 (“CCPA”) and other applicable California privacy laws. This section applies solely to California residents who are users of the Sites (“consumers” or “you”). Any terms defined in the CCPA (such as “personal information”) have the same meaning when used in this section. This section supplements the information contained in our Privacy Policy, which applies to information collected through our Sites.

Categories of Personal Information

We have collected the following categories of personal information in the preceding 12 months:

  • Identifiers, such as name, email address, postal address, account name, unique personal identifier, social media handle, online identifier, IP address or other similar identifiers.
  • Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as name, address, phone number, physical characteristics or employment history.
  • Protected classification characteristics under California or federal law, such as age (40 years or older), race, sex, marital status or medical condition.
  • Commercial information, such as records of personal property, products or services purchased, obtained or considered or other purchasing or consuming histories or tendencies.
  • Internet or other electronic network activity, such as browsing history, search history or information on a consumer’s interaction with a website, application or advertisement.
  • Geolocation data.
  • Professional or employment-related information.
  • Inferences drawn from other personal information to create a profile reflecting the consumer’s preferences, behavior or characteristics.

Categories of Sources

We collect personal information directly from you, indirectly from you (i.e., from observing your actions on the Sites) and from other sources (i.e., information from social media platforms, advertising networks, internet service providers, analytics providers, operating systems and platforms, data brokers, commercially available sources, our affiliates or other business partners).

Business and Commercial Purposes

We use and disclose the categories of personal information listed above for business or commercial purposes. As further described in our Privacy Policy, these purposes include to operate, manage and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives. For example, we use personal information to provide the services on our Sites, such as to create and administer accounts and facilitate the use and enjoyment of forums and communication platforms; fulfill your transactions; respond to your communications; personalize our services and those of our partners and provide you with content of interest (including contextual or targeted ads); conduct research, analytics and data analysis; maintain our facilities and infrastructure; undertake quality and safety assurance measures; conduct risk and security control and monitoring; detect and prevent fraud; perform accounting, audit and other internal functions, such as internal investigations; comply with law, legal process and internal policies; maintain records; facilitate corporate transactions; exercise our rights; and defend legal claims.

Categories of Third Parties

In the preceding 12 months, we have shared the categories of personal information listed above for business purposes with our service providers, business partners and affiliates who assist in providing our services or operating our business. Examples of these third parties include social media platforms, advertising networks, internet service providers, analytics providers, operating systems and platforms, content providers and other business partners.

“Sales” of Personal Information

The CCPA broadly defines “sale” in a way that may include allowing third parties to receive certain data, such as cookie information, IP address or browsing behavior, to deliver targeted advertising on our Services or other sites and apps.

Based on this, in the preceding 12 months, we have “sold” and, subject to your opt-out right described below, may in the future “sell” the following categories of personal information to third parties, including third party advertising networks, social media platforms and other business partners for advertising purposes. Advertising, including targeted advertising, enables us to provide you with certain content for free and to provide you with content and ads that are relevant to you.

We do not have actual knowledge that we sell the personal information of minors under 16 years of age.

Access and Data Portability Rights

Subject to certain exceptions under the CCPA, you have the right to request that we disclose the following information to you:

  • the categories of personal information collected about you;
  • the categories of sources from which the personal information is collected;
  •  
  • the purposes for collecting or sharing personal information;
  • the categories of third parties with which we share personal information for a business purpose;
  • the categories of personal information we have “sold” and, if applicable, the categories of third parties to which we sold personal information; and
  • the specific pieces of personal information we collected about you.
  • Deletion Request Rights

    You have the right to request that we delete the personal information we collected about you, subject to certain exceptions provided by the CCPA. Once we receive and confirm your verifiable request, we will delete the requested personal information from our records, unless an exception provided by the CCPA applies.

    Exercising Your Access, Data Portability or Deletion Rights

    To exercise the access, data portability and deletion rights described above, please submit a verifiable consumer request to us by emailing us at [email protected]

    We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. You will need access to the email account associated with your user account in order to allow us to verify your identity and complete this process. Please describe your request with sufficient detail for us to properly understand, evaluate and respond to it.

    Opt-Out Rights for Personal Information Sales

    Subject to certain exceptions under the CCPA, you have the right to opt out of the future “sale” of your personal information. To do so, you may submit a request by clicking on the “Do Not Sell My Data” link displayed on the homepage or webpage of the Site visited. Your browser must be set to accept cookies. If you access the Site from other devices or browsers, you must submit a request from each device and browser separately. If you delete your cookie history on a particular browser or device, the opt-out will no longer be effective and you will have to submit a new request on that browser or device.

    If you opt out of the future “sale” of your personal information by clicking on the “Do Not Sell My Data” link, that does not mean you will stop seeing ads, but they may not be as relevant or useful to you.

    Requests from Authorized Agents

    If you would like to designate an agent to submit a CCPA request on your behalf, the agent must be registered with the California Secretary of State to conduct business in California. Please send us an email at [email protected] for instructions and details on proof required for use of an authorized agent, including a copy of the written legal authorization signed by the consumer for the agent to act on the consumer’s behalf in this manner.

    Right of Non-Discrimination

    You have the right not to receive discriminatory treatment by us for exercising any of your CCPA rights.

    11. Your Choices

    You may opt out of receiving promotional communications from us at any time by following the unsubscribe instructions included in each communication and/or by selecting your communication preferences in your account or profile, if applicable. Please understand that it may take us a few days to process any opt-out request and that even if you opt out of receiving promotional correspondence from us, we may still contact you in connection with your account, activities, transactions and communications with us.

    You may be able to control the information we received from your device or from third parties (such as social media networks) by changing your device settings, browser settings or privacy settings.

    You may withdraw your consent to our collection, use or disclosure of your personal information, subject to contractual or legal restrictions and reasonable notice. However, if you withdraw your consent to certain collections, uses or disclosures of your personal information, we may not be able to provide you with certain products or services.

    12. How to contact us

    If you have any questions or comments about this Privacy Policy, please contact us at [email protected], or send mail to:

    VerticalScope Inc.
    Attention: Privacy
    111 Peter Street, Suite 901
    Toronto, Ontario, M5V 2H1, Canada
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