Crainstorm Privacy Policy

Welcome to crainstorm.com (the “Site”)!

The Site is provided by UpHouse Inc., and its affiliates (“us”, “we” or “UpHouse”).

This Privacy Policy describes the information we gather from you when you access or purchase or use our products and services through the Site and related products and services (together, the “Services”) and how we use, process, disclose and retain that information. This Privacy Policy has been created in compliance with the Personal Information Protection and Electronic Documents Act (PIPEDA).

By submitting your personal information through our Site and Services, you expressly consent to the transfer of your personal data to our servers in Canada for our collection, use and disclosure in accordance with this Privacy Policy. UpHouse will store the personal information on servers with its services providers.

You can deny or withdraw your consent to UpHouse’s collection, use and disclosure of your personal information at any time upon reasonable notice, subject to any legal or contractual requirements. However, if consent is denied or withdrawn, we may not be able to provide certain Services or use of the Site.

NOTE TO RESIDENTS OF THE EUROPEAN UNION:

In order to comply with the requirements of the European General Data Protection Regulation (“GDPR”) for European users, this Privacy Policy outlines the legal basis on which we process your personal data (also referred to as personal information herein) and provides other information required by the GDPR. We process personal data when we have a lawful basis to do so in accordance with the GDPR. Generally, this means that we process personal data only where we have consent, where necessary to provide you with information, products, or services, or where necessary to comply with our legal obligations. We may also process personal data where otherwise allowed by the GDPR for the purposes outlined in this Privacy Policy (for example, to communicate with you and to respond to your requests). Please see below for further information.

INFORMATION WE COLLECT

When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site (including in connection with the purchase provision of the Services, your usage and activity). We refer to this automatically collected information, collectively, as “Device Information.”

We collect Device Information using the following technologies:

• (a) “Cookies”, which are small data files that are placed on your device or computer by a website and often include an anonymous unique identifier. Among other things, cookies help us improve our Site and your experience. We use cookies to see which Services are popular, to count visits to our Site, and show you personalized ads. By using our Site, you agree that we can place cookies on your device. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org
• (b) “Log files”, that track actions occurring on the Site, and collect data including your Internet Protocol (IP) address, browser type, language, Internet service provider, referring/exit pages, and access date/time stamps.
• (c) “Web beacons,” “tags,” and “pixels”, that are electronic files used to record information about how you browse the Site (including to deliver cookies, count visits and understand usage of the Site).

Additionally, when you fill out an electronic profile on the Site, which is a precondition of purchasing or utilizing any Services, we may collect certain personal information from you, including: your name, email address, address, telephone number, company name, job title and purchase history. We refer to this information, collectively, as “Lead Information.”

For the purpose of this Privacy Policy, Privacy Policy, when we refer to “Personal Information” we are talking both about Device Information and Lead Information.

When we talk about “Personal Information” in this Privacy Policy, we are talking both about Device Information and Order Information.

HOW DO WE USE YOUR PERSONAL INFORMATION?

We use the Lead Information that we collect generally to stay in touch with individuals who we believe to be prospects for our Services! When in line with the preferences you have shared with us, we may provide you with information or advertising relating to our current and future products or services or other developments with respect to UpHouse and its affiliates and partners (in accordance with Canada’s Anti-Spam Legislation).

We use the Device Information to improve and optimize our Site (for example, by generating analytics about how prospects browse and interact with the Site, and to assess the success of our marketing and advertising campaigns) and the Services we provide. This may include merging Personal Information with data obtained from other users, customers, agents or organizations.

We use Personal Information to respond to your comments and questions, provide customer service and otherwise fill your requests, operate and improve our Site and Services. As part of this we may, from time to time, ask you to take part in research & development and surveys used to measure our performance and improve our Site and Services.

We may collect personal information for other purposes where we have a legal duty or right to do so, or where we have a good faith belief that it is necessary to protect the property or rights of UpHouse.

We do not collect Personal Information for any other purposes, except with your consent.

SHARING YOUR PERSONAL INFORMATION

We share your Personal Information with third parties to help us use your Personal Information, as described above. For example, we use Google Analytics to help us understand how our customers use the Site by providing us with analytics services by collecting the type of Personal Information described above: you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.

Other ways we may share your Personal Information with third parties include the following:

• With third party vendors, financial institutions/services, consultants and other service providers
• To provide opportunities to further publicize your own business, such as testimonial/reference provision in media;
• In an emergency, to protect the rights and property of UpHouse, our agents, customers and others; and
• In connection with or during negotiation of any merger, sale of company assets, financing or acquisition of all or a portion of our business to another company.

Some of our affiliates or service providers are located in or store information in the United States of America. As such, your Personal Information may be processed in the United States of America and may be accessible to law enforcement and national security authorities of that jurisdiction. By providing your Personal Information to us, you expressly consent to this.

We may also share aggregated or anonymized Personal Information in a form that does not directly identify you.

Finally, as noted above, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights where we have a good faith belief that it is necessary in order to do so. This includes, but is not limited to, protecting our rights and the rights of our users, enforcing our agreements, policies and terms of use, and protecting, investigating and preventing potentially fraudulent, unauthorized or illegal activities.

We do not otherwise provide or sell our customer/user information to third parties.

PAYMENT INFORMATION

We do not collect payment information on Crainstorm. This is done through Stripe Payments as an API on the Crainstorm web application. By submitting your payment information you are agreeing to the Stripe Terms of Service.

BEHAVIOURAL ADVERTISING

As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

You can opt out of targeted advertising by:

• FACEBOOK
• GOOGLE

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.

DO NOT TRACK

Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.

DATA RETENTION

When you submit your information through the Site, we will maintain your Lead Information for our records unless and until you expressly ask us to delete this information. We retain Personal Information only as long as is reasonable to fulfill the purposes for which the information was collected, or for legal or business purposes.

SECURITY OF YOUR PERSONAL INFORMATION

We take reasonable steps (including physical, technological and organizational measures) to help protect your Personal Information in an effort to prevent loss, misuse and unauthorized access, disclosure, alteration and destruction.

We make every reasonable effort to ensure that Personal Information is accurate and complete. This may involve requesting further information or updates from our users/customers. We rely on individuals to notify us if there is a change in their Personal Information that may affect their relationship with UpHouse.

YOUR INFORMATION CHOICES AND CHANGES 0

You may opt-out of receiving promotional emails from Crainstorm by following the instructions in those emails or by contacting: team@crainstorm.com. If you opt-out of promotional emails, we may still send you non-promotional emails, such as emails about your account or our ongoing business relations (including the Services). You may also make requests about changes to your information or removal of your content by following the directions in your account or by contacting: team@crainstorm.com.

DISCLAIMER

All the information presented on this Site is presented in good faith and believed to be correct. However, we make no representations or warranties as to the completeness or accuracy of this information.

Information is supplied upon the condition that persons receiving it will make their own determination as to its suitability for their use. In no event will UpHouse be responsible for damages of any nature whatsoever resulting from the use or reliance upon this information.

Should you choose to correspond with us with your questions, comments, ideas or suggestions regarding this Site, our products or Services, you agree that, subject to this Privacy Policy, such information shall be deemed as non-confidential and we shall be free to disclose, use and distribute the information to others including but not limited to developing, manufacturing and marketing products and services incorporating the information so provided.

CHANGES TO PRIVACY POLICY

We may update this Privacy Policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.

GDPR INFORMATION

The GDPR sets out obligations and rights with respect to the personal data of residents of the European Union. We are committed to ensuring that we comply with the requirements of the GDPR. As such, this section outlines additional information relevant to residents of the European Union only. Please see the remainder of this Policy for more information on our privacy practices.

Your Rights Relating to Your Personal Data

Subject to some exceptions, the GDPR provides you with the following rights:

• a. Right of access: You have the right to information about whether and why we process your personal data and related information (for example, what personal data we are processing).
• b. Right of rectification: You have the right to correct any inaccurate or incomplete personal data that we hold about you.
• c. Right to erasure: You have the right to ask us to delete personal data that we hold about you.
• d. Right to restrict or object to processing: You have the right to ask us to limit or stop our processing of your personal data in certain cases (for example, if the personal data we are processing about you is inaccurate or is for direct marketing purposes).
• e. Right to data portability: You have the right to ask us for a copy of personal data we hold about you and to transfer such data to another entity.
• f. Right to complain: We encourage you to contact us at the contact information below if you have any questions or concerns with our personal data practices. However, you also have the right to complain to regulatory authorities in your jurisdiction. Please contact us at the contact information below if you need information about the appropriate authority.

You may exercise these rights or find out more about these rights by contacting us at the contact information listed below.

Retention and Storage of Personal Data

We are based in Canada and processes personal data in Canada. The European Commission recognizes Canada as providing an adequate level of protection for personal data. Our service providers may process your personal information outside of Canada (such as in the United States of America). When your information is processed outside of the European Union, it may be subject to the laws of and be accessible by legal authorities in such other jurisdictions. We have taken appropriate technical, organizational, and legal steps to secure this information.

QUESTIONS/CONTACT US

For more information about our privacy practices, if you have questions regarding our Privacy Policy, corrections, edits to or the security of your Personal Information, or if you would like to make a complaint, please contact us by e-mail at team@crainstorm.com or by mail using the details provided below: Arthur Street, 705, Winnipeg, MB, R3B 1G7, Canada, Attention: Privacy Officer.