Privacy | Id Caddie

ID Caddie Inc. Privacy Policy

Effective Date: Wednesday, December 13th, 2023

Last modified: Wednesday, December 13th, 2023

1. PURPOSE AND SCOPE

ID Caddie Inc. and our affiliates and subsidiaries (“Company”, “Our”, “Us” or “We”) are committed to protecting the information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household received from You directly pursuant to or in connection with the Platform Personal Information (“Personal Information” or “Personal Data”) of our customers and website users (“You”) from unauthorized collection, access, use, or disclosure, theft or loss. We value your privacy and are committed to being accountable for how we treat your personal information. All employees, partners and affiliates are required to adhere to the protections described in this policy.

Personal Information is considered any information (factual or subjective, recorded or not) about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person. Personal information does not include business contact information, including your name, title, or business contact information.

This Privacy Policy (the “Policy”) addresses the appropriate collection, use and disclosure of personal information, the individual’s right to limit access to his/her record, and the secure disposal of the data when it is no longer required.

In this Policy, we explain how we collect, use and disclose your personal information that we obtain when you use our services, visit or use our website https://www.idcaddie.com or use our chrome app “ID Caddie” (our “Platform”), or otherwise interact with us, and the steps we take to protect your Personal Information. The purpose of this Policy is to inform you of our privacy practices including:

• a description of the types and categories of Personal Information we collect, or may collect about you;
• how we collect your Personal Information;
• the purposes for which we collect, use and disclose your Personal Information (i.e., why we collect it);
• how we use or intend to use your Personal Information;
• how to obtain access or request correction of your Personal Information;
• with which parties we may share your Personal Information;
• and to provide you with contact information should you have questions or concerns about our practices.

This Policy should be read in conjunction with the Terms of Service of the Platform.

Please read this policy carefully to understand our policies and practices for collecting, processing, and storing your information. If you do not agree with our policies and practices, please do not use our Platform. By accessing or using this Platform, you indicate that you understand, accept, and consent to the practices described in this policy. This policy may change from time to time. Your continued use of this Platform after we make changes indicates that you accept and consent to those changes, so please check the policy periodically for updates.

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1. https://www.okta.com/privacy-policy/#iii-personal-data-we-collect-and-data-sources-2
2. II. ID Caddie’s Roles & Responsibilities

ID CaddieThe Company is the controller of your Personal Data, as described in this Privacy Policy, unless otherwise stated. Please note that this Privacy Policy does not apply to the extent that we process Personal Data in the role of a processor (or a comparable role such as a “service provider” in certain jurisdictions) on behalf of our customers, including where we offer to our customers various cloud products and services, through which our customers (and/or their affiliates) connect their own websites and applications to our hosted platform, sell or offer their own products and services, send electronic communications to other individuals, or otherwise collect, use, share or process Personal Data via our cloud products and services.

Each of our customers, not ID Caddiethe Company, controls whether what Personal Data they provide put inyou with an account or other access to the ID CaddieCompany’s cloud servicePlatform through their subscription, and if they provide you such Personal Data with such accounts or other access through their subscription, they control what Personal Data information about you that they submit to our servicePlatform. This content may include contact information (such as your first and last names, email address, and phone number), professional information (such as the department you work information for at youror place of employment), or other types of information that a customer chooses to submit. Use of this content by ID Caddiethe Company is governed by agreements between the Company ID Caddie and the Customer.

For detailed privacy information applicable to situations where a n ID Caddie customer of the Company (and/or a customer affiliate) who uses ID Caddie cloud products and servicesthe Platform is the controller, please reach out to the respective customer directly. We are not responsible for the privacy or data security practices of our customers, which may differ from those set forth in this Privacy Policy. If not stated otherwise either in this Privacy Policy or in a separate disclosure, we process such Personal Datadata in the role of a processor or service provider on behalf of a customer (and/or its affiliates), who is the responsible controller of the applicable Personal Datadata.

If you are a Platform user but not a customer, and your Personal Data has been submitted to us by or on behalf of a Company n ID Caddie customer and you wish to exercise any rights you may have under applicable data protection laws, please inquire with the applicable customer directly. Because we may only access a customer’s data upon instruction from that customer, if you wish to make your request directly to us, please provide to us the name of the ID Caddie customer who submitted your Personal Data to us. If we are able to verify the ID Caddie customer, we will refer your request to that customer and support them as needed in responding to your request within a reasonable timeframe.

Additional information and safeguards regarding ID Caddie’s data protection obligations (including for international transfers) to our customers are set forth in our subscription agreement form and related documents, including our Trust & Compliance Documentation, all of which are available online at www.idcaddie.com/terms

3. OVERVIEW OF OUR PRIVACY PRACTICES

Our privacy practices are summarized here. The Company:

1. collects Personal Information when you access or provide information through our website or make inquiries with us;

2. may collect non-identifiable information regarding users, including but not limited to the date and time users access our Platform, Internet protocol (IP) address, cookies and web beacons;

3. shares your Personal Information with our authorized employees, agents, service providers and legal representatives, and may also share this information with third parties engaged to provide products and services on our behalf (“Third Parties”). When connecting to a Third-Party website within our website, such use is governed and controlled by the terms and conditions for those Third Parties. ID Caddie Inc does not control the terms of Third Party web sites. We may however, share your Personal Information with these Third Parties in order to fulfil the services you have requested through the use of our Platform;

4. will not share your Personal Information with Third Parties without your consent, except as set out in (3), unless you have (i) authorized us to do so; (ii) as required by law; or (iii) as disclosed to you when the Personal Information is collected;

5. may collect and use your Personal Information to comply with applicable laws and regulations, to administer our Platform, to protect you and us from fraud or other illegal activities, to contact you regarding your inquiries, and to communicate with you (provided you have opted to receive such information);

6. allows you to withdraw your consent to the collection, storage, use, disclosure and retention of your Personal Information at any time by contacting us at to support “at” idcaddie “dot” com.

7. will mitigate the risk and impact of potential harms involved in the disclosure of Personal Information through the adoption of reasonable physical, technical and organizational procedures appropriate to the sensitivity of the data in an effort to safeguard the Personal Information you provide to us.

To assist with meeting our privacy obligations, we have designated a contact person, the Corporate Privacy Officer, who is accountable for ID Caddie’s compliance with applicable privacy legislation.

ID Caddie adheres to the privacy principles set out by the Canadian Standards Association (CSA). The CSA’s ten privacy principles serve as the basis of Canada’s Federal Privacy Legislation, PIPEDA. These principles form the basis of our Privacy Policy and how ID Caddie collects, uses, discloses and safeguards the personal information we hold about you.      

Privacy Principles

1. Accountability: We are responsible for the collection, use and disclosure of personal information in our custody or control. Our privacy contact person is accountable for compliance with our Privacy Policy and can be reached by email to support “at” idcaddie “dot” com 18 King E St, Suite 1400, Toronto, Ontario, Canada, M5C 1C4or telephone at [my number? Do we need a number? I’ll get a digital one if we doXXX]. .

2. Identifying purposes for collecting personal information: We will identify the purposes for which personal information is collected at or before the time the information is collected.

3. Consent for collection, use, and disclosure of personal: information Your knowledge and consent are required for the collection, use or disclosure of personal information, except where otherwise permitted or required by law

4. Limiting collection of personal information: We will limit the collection of personal information to that which is necessary for the authorized purposes identified. Information will be collected by fair and lawful means.

5. Limiting use, disclosure, and retention of personal information: Personal information will not be used or disclosed for purposes other than those for which it was collected. Personal information will be retained only as long as necessary to fulfil those purposes.

6. Accuracy of personal information: Personal information will be as accurate, complete and up to date as is necessary for the purposes for which it is to be used.

7. Ensuring safeguards for personal information: Personal information will be protected by security safeguards appropriate to the nature and format of the information being stored

8. Openness about privacy policy: We will provide you with specific information about our policies and practices relating to how we manage your personal information.

9. Individual access to personal information Upon your written request, we will inform you of the existence, use and disclosure of your personal information and will give you access to that information, with limited exceptions. You may challenge the accuracy and completeness of the information and may request to have it amended.

10. Challenging compliance with the privacy policy. You may address a challenge or complaint concerning compliance with the above principles to our Privacy Officer at support “at” idcaddie “dot” com to the relevant regulatory oversight body. For details on the various relevant privacy authorities, see section 19 of this policy.

4. PERSONAL INFORMATION WE COLLECT ABOUT YOU

We collect only the information that is required to fulfil the purposes described in this Policy. We do not collect any other information, or allow information to be used for other purposes, without your express (i.e., verbal, written or electronic) consent - except where authorized to do so by law. We maintain information relating the users of our Platform and the information they provide. Only Personal Information that is reasonably necessary is collected.

We collect and use several types of information from and about you, from various sources including:

(a) Information You Provide the Company Which Is Necessary to Use Our Services

We ask for and collect the following personal information about you when you use our Platform. This information is necessary for the adequate performance of the contract between you and us and to allow us to comply with our legal obligations and provide you with our Services. Without it, we may not be able to provide you with all the requested Services.

• Account or Registration Information. When you sign up for a Company account, or subscribe to our services, we require certain information to create your account, such as your contact information, including your name, business name, username, password, billing address, e-mail address.
• Third-Party Authentication. If you choose to sign in with a third-party authentication service, such as Google Sign-In, please be aware that the third-party provider may collect and retain personal information according to their own privacy policies. We recommend reviewing these policies before choosing to sign in with a third-party service.

(b) Information You Choose to Give Us

You can choose to provide us with additional personal information. This information may include:

• Additional Profile Information. Such as your industry type, preferred language(s), city, and telephone number.
• Other Information. Such as when you fill in a form, add information to your account, respond to surveys, provide reviews of our services, participate in promotions. We may collect records and copies of your correspondence (including email addresses and chat sessions), if you contact us or otherwise communicate with our customer service team, or share your experience with us.
• You may also provide information to be published or displayed (hereinafter, “posted”) on public areas of the Platform or transmitted to other users of the Platform or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Additionally, we cannot control the actions of other users of the Platform with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that unauthorized persons will not view your User Contributions. (This user contribution isn’t relevant now, I guess we should remove? For simplicity?)

When you use our Platform or Services, we automatically collect personal information. This information may include:

• Geo-location Information. Such as precise or approximate location determined from your IP address or mobile device’s GPS depending on your device settings. Most mobile devices allow you to control or disable the use of location services for applications in the device’s setting menu.We may also collect this information when you’re not using the app if you enable this through your settings or device permissions. (will be coming but don’t do yet)
• Usage Information. We collect information about your interactions with the the Company Platform, such as the pages or content you access on our Platform, how long you spend on a particular page. products you viewed or searched for on our Platform, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page and other information derived from your access and usage of our website information you input into our Platform (such as search terms in the search bar), any links you click on, and similar information.
• “Aggregate Information” means information about users we may collect to create information that is aggregated and anonymized that cannot be used to identify any natural person. We may collect aggregate information in order to develop statistics and analytics about our Platform and improve the user experience and the delivery of our services. For example, we may aggregate personal information to calculate the percentage of users accessing a specific Platform feature. Though Aggregate Information may be derived from Personal Information, it is not considered Personal Information because it cannot be used to identify any natural person.
• Log Data and Device Information. We automatically collect log data and device information when you access and use our Platform, even if you have not created an. Account or logged in. That information includes, among other things: details about how you’ve used our Platform, including if you clicked on links to third party applications), IP address, MAC address, access dates and times, hardware and software information, browser type and version, time-zone settings, browser plug-in types, operating system, information about your internet connection, device information, device event information, unique identifiers, crash data, cookie data, and the pages you’ve viewed or engaged with before or after using our Platform.
• Cookies and Similar Technologies. We use cookies and other similar technologies when you use our platform, use our mobile app, or engage with our online ads or email communications. We may collect certain information by automated means using technologies such as cookies, web beacons, pixels, browser analysis tools, server logs, and mobile identifiers. “Cookies” are small files that are saved onto your device or browser through your web browser that allow us to collect certain Usage Information, and “pixel tags” are tiny graphics with unique identifiers that are embedded on the Platform that allow us to collect certain Usage Information. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Platform. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Platform.
• Web beacons. Pages of our Platform and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
• Pixels and SDKs. Third parties, including Facebook, may use cookies, web beacons, and other storage technologies to collect or receive information from our websites and elsewhere on the internet and use that information to provide measurement services and target ads. For apps, that third parties, including Facebook, may collect or receive information from your app and other apps and use that information to provide measurement services and targeted ads. Users can opt-out of the collection and use of information for ad targeting by updating their Facebook account ad settings and by contacting us with a description of your request and validation information.
• Do Not Track Signals. While you may disable the usage of cookies through your browser settings, our Platform currently does not respond to a “Do Not Track” signal in the HTTP header from your browser or mobile application due to lack of standardization regarding how that signal should be interpreted.

The Company and its third-party vendors (including Google Analytics, who provides additional privacy notices here) may use Tracking Technologies, such as cookies and pixel tags, to collect Usage Information. Tracking Technologies do not, by themselves, collect Personal Information; however, we may use Tracking Technologies to, for example, identify that the device you are using has accessed certain parts of the Platform and may associate that information with Personal Information you have voluntarily provided us.

Please note that you have choices with respect to the use of Tracking Technologies and may, in some instances, disable them depending on your preferences.

(d) Information from Third Parties

Ancillary Data. For the ID Caddie chrome app product, data collected may include the applications that are installed on your device. Collectively, we refer to this data as “Ancillary Data”. Some of the Ancillary Data, including Usage Data, that we receive is dependent on your organization’s policies and settings and what information it permits to be shared with ID Caddie. ID Caddie uses Ancillary Data to improve security and to provide and improve its products to customers, including to better understand customer behavior in order to create new features and provide threat-related insights for our customers.

Some of these products that collect and process Ancillary Data include:

• the ID Caddie browser plugin;

Through the ID Caddie browser plugin, the Ancillary Data we collect includes details about your login session, IP address, user-agent, and the web application name, email addresses on that website, and website address, as well as other information that is not personal in nature. In addition, as part of Ancillary Data, we may collect interaction data about your use of the ID Caddie browser plugin. We use the information collected through the ID Caddie browser plugin for security purposes and to provide features, such as to allow you to better manage the users for websites that you visit.

We collect Personal Information from other sourcesthird parties, such as:

• Third-Party Service Providers. Some content or applications on the Platform, including advertisements, are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Platform. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioural) advertising or other targeted content.

You can opt-out of several third-party ad servers' and networks' cookies simultaneously by using an opt-out tool created by the Digital Advertising Alliance of Canada. You can also access these websites to learn more about online behavioural advertising and how to stop websites from placing cookies on your device. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.

We do not control these third parties' tracking technologies or how they are used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

• ID Caddie Chrome Extension. Through the ID Caddie Chrome extension, we collect and process data that may include data from applications that are installed on your device, such as Usage Data including details about your login session, IP address, user-agent, and the web application name, email addresses on that website, and website address, as well as other information that is not personal in nature (“Ancillary Data”). Some of the Ancillary Data that we receive is dependent on your organization’s policies and settings and what information it permits to be shared with the Company. The Company uses Ancillary Data to improve security and to provide and improve its products to customers, including to better understand customer behavior in order to create new features and provide threat-related insights for our customers.

• Other Sources. To the extent permitted by applicable law, we may receive additional information about you, such as demographic data or information to help detect fraud and safety issues, from third party service providers and/or partners, and combine it with information we have about you. For example, we may receive background check results (with your consent where required) or fraud warnings from service providers like identity verification services for our fraud prevention and risk assessment efforts.

5. HOW WE USE YOUR INFORMATION

We may use, store, and process personal information to (i) provide, improve, and develop our Platform and Services, (ii) to perform our legal obligations and enforce our policies, and (iii) provide, personalize, measure, and improve our advertising and marketing.

a. Provide, Improve, and Develop our Platform and Services, including to: We use personal information to:

• enable you to access and use the Platform and our Services,
• perform analytics, debugging and conduct research,
• provide you with information, products, or services that you request from us.
• provide customer service or handle customer complaints,
• send you messages, updates, security alerts, and account notifications,
• To notify you about changes to our Platform or any products or services we offer or provide though it,
• to operate, protect, improve, our Platform and Services, and personalize and customize your experience (based on your preferences).

b. Perform our Legal Obligations and Enforce our Policies: We may use personal information to:

• detect and prevent fraud, spam, abuse, security incidents, and other harmful activity,
• conduct security investigations and risk assessments,
• verify or authenticate information provided by you,
• comply with our legal obligations,
• enforce our agreements with your or our third-parties,
• enforce our Terms of Service and other policies.

c. Provide, Personalize, and Improve our Advertising and Marketing. We may use personal information to:

• send you marketing, advertising or promotional messages or materials, and other information based on your preferences,
• personalize, measure, and improve our advertising,
• administer surveys, sweepstakes, contests, or other promotional activities sponsored or managed by the Company or its third-party partners; and
• analyze characteristics and preferences to send you promotional messages, marketing, advertising and other information that we think might be of interest to you (based on your preferences).

If you do not want us to use your information to promote our services to you, please use the unsubscribe mechanism, located at the bottom of our e-mails. We provide an opportunity for any user to unsubscribe from our services or opt-out of contact for marketing purposes on an ongoing basis by using the unsubscribe mechanism at the bottom of our e-mails, or e-mailing to support “at” idcaddie “dot” com.

We may use the information we have collected from you to enable us to display advertisements to our advertisers' target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

5. SHARING AND DISCLOSURE OF YOUR INFORMATION

We will keep Personal Information that you provide to us private and will disclose such Personal Information only in accordance with this Policy. We do not sell, rent, or lease to third parties any Personal Information we collect from you.

We share your information as needed to fulfill the purposes described in this Privacy Policy and as permitted by applicable law. This includes sharing among our affiliated entities for internal business purposes, sharing with service providers, sharing with your consent, sharing for marketing purposes, sharing as part of corporate transactions, and sharing to protect lawful interests.

We may share your information in the following circumstances:

• With Our Subsidiaries or Affiliates – We may share information between and among the Company, its subsidiaries, and affiliated companies. For example, we may share your information with our subsidiaries and affiliated companies to process orders and requests, and expand and promote our product and service offerings.
• With Our Service Providers – We may share your information with service providers that provide us with support services, such as credit card processing, website hosting, email and postal delivery, location mapping, product and service delivery, or analytics services. We aim at contractually prohibit these service providers from retaining, using, or disclosing your confidential personal information for any purpose other than performing agreed upon services for us. We strive to ensure that our Service Providers process the personal information with the same standards set out in this policy.
• In the Context of Corporate Transactions – If we become involved with a merger, divestiture, restructuring, reorganization, dissolution, sale or transfer, or other corporate transaction or another situation involving the transfer of some or all of our business assets, we may share your information with business entities or people involved in the negotiation or transfer.
• To Protect Property, Safety and Compliance with Applicable Law – We may disclose your information if we believe that the disclosure is required by law, if we believe that the disclosure is necessary to enforce our agreements or policies, or if we believe that the disclosure will help us protect the rights, property, health or safety of our customers or partners. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction. We may share your personal information enforce or apply our Terms of Service www.idcaddie.com/terms and other agreements, including for billing and collection purposes.
• With Our Marketing Service Providers – We may share your information with marketing service providers to assess, develop and provide you with promotions and special offers that may interest you, administer contests, sweepstakes and events or for other promotional purposes.
• With Your Consent – We may share information about you with other companies if you give us permission or direct us to share the information.
• When the Information Does Not Identify You – We may share your information in a way that does not directly identify you. For example, we may share information about your use of our websites in a manner that does not identify you, or we may combine information about the nature or frequency of your transactions with similar information about other people and share the aggregated information for statistical analysis and other business purposes.
• When You Provide Information on Our Platform – If you post information, such as a review, on our Platform, the information that you post may be seen by other visitors to our websites, including your user name.

We may transfer personal information that we collect or that you provide as described in this policy to authorized employees, agents, legal representatives, contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Platform administration, improvement and optimization) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy. Please note that third-party providers may change from time to time.

We may process, store, and transfer your personal information in and to a foreign country, with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information through the laws of the foreign country. Whenever we engage a service provider, we require that its privacy and security standards adhere to this policy and applicable Canadian privacy legislation.

By submitting your personal information or engaging with the Platform, you consent to this transfer, storage, or processing.

6. HOW LONG WE KEEP YOUR PERSONAL INFORMATION

In accordance with our Data Retention Policy, except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We will ensure that your records are disposed of in a secure and privacy protective manner.

Under some circumstances we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.

In certain jurisdictions, you can request to have all your personal information deleted entirely. Please note that if you request the erasure of your Personal Information:

• We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety.
• We may retain and use your personal information to the extent necessary to comply with our legal obligations.
• Information you have shared with others (e.g., reviews)
• Because we protect your Personal Information from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.

7. CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website. If you disable or refuse cookies, please note that some parts of this Platform may not be accessible or may not function properly.
• Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by sending us an email stating your request to support “at” idcaddie “dot” com
• Promotional Offers from the Company. If you have opted in to receive certain emails from us but no longer wish to have your email address/contact information used by the Company to promote our own or third parties' products or services, you can opt-out by sending us an email stating your request to support “at” idcaddie “dot” com. If we have sent you a promotional email, you may unsubscribe by clicking the unsubscribe link we have included in the email. This opt-out does not apply to information provided to the Company as part of a purchase, product service experience, or other transactions.

We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of several third-party ad servers' and networks' cookies simultaneously by using an opt-out tool created by the Digital Advertising Alliance of Canada. You can also access these websites to learn more about online behavioural advertising and how to stop websites from placing cookies on your device. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.

8. HOW WE SECURE YOUR PERSONAL INFORMATION

Safeguards are in place to protect the security of your information. We keep the Personal Information we collect about you confidential and have adopted reasonable physical, technical and organizational procedures appropriate to the sensitivity of the data to safeguard the Personal Information you provide to us. These safeguards are aimed at protecting personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification.

Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Platform. Notwithstanding the security measures we have in place, no collection, storage or transmission of information over the Internet on websites or otherwise can be guaranteed to be completely secure, and therefore we cannot ensure, warrant or guarantee the security of any such information. As a result, we cannot warrant the security of any information you transmit to us, and you do so at your own risk.

Where we have given you (or where you have chosen) a password for access to certain parts of our Platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Platform like message boards, which any Platform visitor can view.

9. CHILDREN UNDER THE AGE OF 13

Our Platform is not intended for children under 13 years of age. No one under age 13 may provide any information to or on the Platform. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Platform or on or through any of its features/register on the Platform, make any purchases through the Platform, use any of the interactive or public comment features of this Platform, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or username you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at support “at” idcaddie “dot” com

10. THIRD PARTY HYPERLINKS

Our Platform may contain hyperlinks to the websites of third parties. We are not responsible for the privacy practices or the content of such other websites. Linked websites are maintained by third parties. Such links are provided for your convenience and reference only. The Company does not operate or control, in any respect, any information, software, products or services available on such third-party websites. The inclusion of a link to such website does not imply any endorsement of the services or the site, its contents, or its sponsoring organization. We strongly advise you to review the privacy policy of every website you visit.

11. ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes. By law you have the right to request access to and to correct the personal information that we hold about you.

You can review and change your personal information by logging into the Platform and visiting your account profile page.

If you want to review, verify, correct, or withdraw consent to the use of your personal information you may also send us an email at support “at” idcaddie “dot” com to request access to, correct, or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

We will provide access to your personal information, subject to exceptions set out in applicable privacy legislation. Examples of such exceptions include:

• Information protected by solicitor-client privilege.
• Information that is part of a formal dispute resolution process.
• Information that is about another individual that would reveal their personal information or confidential commercial information.
• Information that is prohibitively expensive to provide.

12. WITHDRAWING YOUR CONSENT

Where you have provided your consent to the collection, use, and transfer of your personal information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us at support “at” idcaddie “dot” com. Please note that if you withdraw your consent we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision.

13. CHANGES TO OUR PRIVACY POLICY

the Company reserves the right to modify this Privacy Policy at any time, and from time to time, in accordance with this provision. If we make changes to this Policy, we will post the revised Privacy Policy on our Platform and update the “Last Modified” date at the top of this Policy. 

If we make material changes to how we treat our users' personal information, we will notify you by email to the primary email address specified in your account or through a notice on the Platform home page.

You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you, and for periodically visiting our Platform and this privacy policy to check for any changes.

If you disagree with the revised Policy, you may cancel your account. If you do not cancel your account before the date the revised Policy becomes effective, your continued access to or use of the Platform or our Services will be subject to the revised Policy and you will be deemed to have consented to the revised Policy.

1. SEVERABILITY
14.

If any term, provision, covenant, or condition of this Policy is held invalid or unenforceable for any reason, the remainder of the provisions shall continue in full force and effect as if this Policy had been executed with the invalid portion thereof eliminated.

15. CONTACT INFORMATION AND CHALLENGING COMPLIANCE

We welcome your questions, comments, and requests regarding this privacy policy and our privacy practices. Please contact us at:

Privacy Officer

support “at” idcaddie “dot” com

18 King E St, Suite 1400, Toronto, Ontario,

Canada, M5C1C4

We have procedures in place to receive and respond to complaints or inquiries about our handling of personal information, our compliance with this policy, and with applicable privacy laws. To discuss our compliance with this policy please contact our Privacy Officer using the contact information listed above.