Approvalwise™ Privacy Policy

Last Updated: January 1, 2022

Approvalwise Inc. (“Approvalwise”, “we”, “us”) has created this Privacy Policy (“Privacy Policy”) to set out how we collect, use, and disclose information about identifiable individuals and information which can be used to identify an individual (“Personal Information”) through our Website, https://approvalwise.com/ and its subpages (the “Website”) and in the course of providing access to and services on our web platform (collectively, all of the foregoing the “Services”).

Approvals drive sales.

Privacy is of great importance to us. We do not actively collect Personal Information for the purpose of selling or marketing that Personal Information to third parties. Personal Information may be collected about users and visitors to the Website, as well as our customers and their end users who interact with our Services. By visiting our Website or using the Services in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy and you hereby consent to the collection, use and disclosure of your Personal Information in accordance with this Privacy Policy.

1. OVERVIEW

1.1. A Note About Children. We do not intentionally gather Personal Information from persons who are under the age of 13. If a child under 13 submits Personal Information to Approvalwise and we learn that the Personal Information is the Personal Information of a child under 13, we will attempt to delete the Personal Information as soon as possible. If you believe that we might have any Personal Information from a child under 13, please contact us at [email protected].

1.2. International Users. If you are a non-U.S. or non-Canadian user of the Services, by visiting the Services and providing us with data, you acknowledge and agree that your Personal Information may be processed for the purposes identified in this Privacy Policy. In addition, your Personal Information may be processed in the country in which it was collected and in other countries, including the United States and Canada, where laws regarding processing of Personal Information may be less stringent than the laws in your country. By providing your data, you consent to such transfer. If you are in the UK or EEC please see specific terms which apply to you further below.

1.3. Lawful processing. We process your Personal Information only to the extent necessary for the purposes described in this Privacy Policy. We set out below the type of Personal Information we collect and how we use such Personal Information. Except as set forth in this Privacy Policy, your Personal Information will not be used for any other purpose without your consent. You may withdraw your consent to our processing of your Personal Information at any time. However, withdrawing consent may result in your inability to continue using the Services.

1.4. Scope. This Privacy Policy covers the activities of Approvalwise but does not apply to the practices of companies that we do not own or control, including other sites linked from our Services. You are responsible for ensuring that you have obtained the necessary authorizations and consents for any Personal Information you make available to us for use in accordance with this Privacy Policy, in particular, you represent and warrant to Apprvovalwise that you have the necessary rights under applicable law or have obtained the necessary consents to provide such Personal Information in order to allow Approvalwise to use, disclose and otherwise process such Personal Information for the purposes described in this Privacy Policy in the manner described in this Privacy Policy.

2. COLLECTION AND USE OF PERSONAL INFORMATION

2.1. What we Collect. Set out below are the ways in which we may collect Personal Information:

• Personal Information We Collect from our Customers. We may collect business contact information of individuals in order to communicate with those customers and respond to inquiries relating to the provision and management of our Services. Such information may include your name, organization name, email address and telephone number.
• Device information. We may collect information about devices you use to access the Services and information about how you use the Services, such as your IP address and which websites you visited before accessing our Services.
• Logs. Our servers automatically record information created by your use of our Services to help us diagnose and fix technical issues, and to improve the overall quality and user experience of our Services. Logs may include information such as your IP address, browser type, operating system, details of how you used our Services (such as the functions you asked our Services to perform), diagnostic information related to the Services (such as crash activity reports), the referring web page, pages visited, location, your mobile carrier, device and application IDs, search terms, and cookie information.
• Cookies. We use technologies like cookies and pixel tags to gather information about how you are interacting with the Services, which may include identifying your IP address, browser type, and referring page.
• Marketing Information. From time to time, we may conduct surveys or hold contests or other events and in connection with such surveys, contests, or events, we may collect information you elect to provide about yourself, such as your name, email address, telephone number, organization name and address; and general information about the company for whom you work.

2.2. Use of Personal Information. Approvalwise uses the Personal Information described above to:

• provide, operate, maintain and improve the Services;
• send notices, updates, security alerts and support and administrative messages;
• respond to comments, questions, and requests and provide customer service and support;
• communicate with you and provide news or information about us;
• investigate and prevent fraudulent transactions, unauthorized access to the Services, and other illegal activities;
• monitor and analyze trends, usage, and activities in connection with the Services, including generating aggregated and anonymized statistics;
• conduct business and contractual relationships that we have with various persons and companies (such as customers, suppliers, partners and employees); and
• for other purposes which we will notify you about and seek your consent.

3. STORAGE LOCATION AND TRANSFER OF PERSONAL INFORMATION.

Approvalwise’s headquarters in Canada is our primary location for business operations. Servers hosting the Approvalwise platform are located in Canada and the United States. Approvalwise also transfers data to third-party service providers, including the third-party service providers described in the Sub-Processors section (“Sub-Processors”) below. You agree to this transfer, storing or processing of your Personal Information as set out herein and accordingly, your Personal Information may be accessible to law enforcement and governmental agencies under lawful access regimes or court order in the jurisdiction that the Personal Information is stored.

4. DISCLOSURE OF PERSONAL INFORMATION WITH THIRD PARTIES

4.1. Service Providers and Business Partners. We may from time to time employ third parties to perform tasks for us and we may need to share Personal Information (including account information) with them to perform those tasks. Unless we tell you differently, such third parties do not have any right to use the Personal Information we share with them beyond what is necessary for them to perform the relevant tasks for us. The third parties we currently engage include third-party companies and individuals employed or contracted by us to provide certain capabilities within the Services and for certain general business functions, including the provision of database management, payment processing and customer relationship management tools, including the Sub-Processors.

4.2. Business Transfers. If our business (or substantially all of our assets) are acquired by a third party, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information may be made available or otherwise transferred to the new controlling entity, where permitted under applicable law. Your Personal Information may also be transferred in connection with due diligence for any such transactions. In all cases, if any such transactions occur, your Personal Information will remain subject to the restrictions and protections set forth in this Privacy Policy.

4.3. With Your Consent. If we need to use or disclose any Personal Information in a way not identified in this Privacy Policy, we will notify you and/or obtain consent as required under applicable privacy laws.

4.4. As Required by Law. We may disclose your Personal Information to third parties without your consent if we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other users, or anyone else (including the rights or property of anyone else) that could be harmed by such activities. Further, we may disclose Personal Information when we believe in good faith that such disclosure is required by and in accordance with the law.

We also reserve the right to access, read, preserve, and disclose any information as we reasonably believe is necessary to:

• satisfy any applicable law, regulation, legal process or governmental request (including in pursuant to subpoenas, civil investigative demands, or similar processes); enforce our contracts or user agreements, including investigation of potential violations hereof; and
• detect, prevent, or otherwise address fraud, security, or technical issues.

The above may include exchanging information with other companies and organizations for fraud protection, spam/malware prevention, and know-your-customer purposes. Notwithstanding the general terms of this policy, the collection, use, and disclosure of Personal Information may be made outside of the terms of this Privacy Policy to the extent provided for in any applicable privacy or other legislation in effect from time to time, or pursuant to court orders (including in respect to depositions, interrogatories, subpoenas, civil investigative demands, and other court or regulatory-mandated discovery processes).

5. RETENTION.

Approvalwise will keep Personal Information for as long as it remains necessary for the purpose identified in this Privacy Policy or as required by law, which may extend beyond the termination of our relationship with users. If a user requests that person’s name be removed from our databases, it may not be possible to completely delete all Personal Information due to legal constraints. In addition, the premature deletion or destruction of certain data could be prejudicial to our ability to address claims, deal with operational difficulties or meet regulatory or legal obligations. Accordingly, we may retain certain data (which may include personal Information) (in order to fulfil our contractual, statutory or regulatory requirements and/or to meet our operational needs and to preserve information which has historic value. All retained Personal Information will remain subject to the terms of this Privacy Policy.

6. Residents of the European Economic COMMUNITY (“EEC”) AND THE UK

If you are a resident of the EEC or the UK, you have certain data protection rights. Approvalwise takes reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Information (known as “Personal Data” under the EU General Data Protection Regulation and under the UK Data Protection Act 2018).

If you wish to be informed about what Personal Data we hold about you and if you want that Personal Data to be removed from our systems, please contact us using the contact information set out below. Note that where we act as a data processor on behalf of our customers, you will be required to contact the data controller directly to exercise your rights.

In certain circumstances, where we act as data controller, you have the following data protection rights:

• Request access to your Personal Data (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Data we hold about you where we are the data controller and to check that we are lawfully processing it.
• Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us.
• Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios: (a) if you want us to establish the information's accuracy; (b) where our use of the information is unlawful but you do not want us to erase it; (c) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
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• Withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local Data Protection Authority. If you wish to exercise any of the rights set out above, please contact us using the contact details below.

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it.

We may also contact you to ask you for further information in relation to your request to speed up our response.

7. ACCESS, CORRECTION AND ACCURACY.

You have the right to access the Personal Information we hold about you in order to verify the Personal Information we have collected in respect to you and to have a general account of our uses of that Personal Information. Upon receipt of your written request, we will provide you with a copy of your Personal Information, although in certain limited circumstances, and as permitted under law, we may not be able to make all relevant Personal Information available to you, such as where that Personal Information also pertains to another individual. In such circumstances we will provide reasons for the denial to you upon request. We will endeavor to deal with all requests for access to and modifications of Personal Information in a timely manner.

We will make every reasonable effort to keep your Personal Information accurate and up to date, and we will provide you with mechanisms to update, correct, delete or add to your Personal Information as appropriate. As appropriate, this amended Personal Information will be transmitted to those parties to which we are permitted to disclose your Personal Information. Having accurate Personal Information about you enables us to give you the best possible service.

8. CALIFORNIA PRIVACY RIGHTS.

This section provides additional details about the Personal Information we collect about California consumers and the rights afforded to them under the California Consumer Privacy Act (the CCPA).

For more details about the Personal Information Approvalwise has collected over the last 12 months, please see the section “Information you provide us” above. We collect this Personal Information for commercial purposes described above. Approvalwise does not sell (as that term is defined in the CCPA) the Personal Information we collect.

Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of Personal Information we collect about them (including how we use and disclose this Personal Information), to delete their Personal Information, to opt out of any “sales” of Personal Information that may be occurring, and to not be discriminated against for exercising these rights.

California consumers may make a request pursuant to their rights under the CCPA by contacting us at the contact information below. We will verify your request using the information (including Personal Information) associated with your account, if available, including email address. Government identification may be required. Consumers can also designate an authorized agent to exercise these rights on their behalf.

9. CHANGES TO THIS PRIVACY POLICY.

We may amend this Privacy Policy from time to time. Processing of Personal Information we collect is subject to the Privacy Policy in effect at the time such Personal Information is collected, used or disclosed as this Privacy Policy may subsequently be updated in accordance with this Section 9. If we make material changes or changes in the way we use Personal Information, we will notify you by posting an announcement on our Website or via the Services or sending you an email prior to the change becoming effective. You are bound by any changes to the Privacy Policy when you use the Website or Services after such changes have been first announced.

10. ADDITIONAL INFORMATION.

Questions regarding this Privacy Policy or Approvalwise’s privacy practices should be directed to our Privacy Officer: Approvalwise Inc., Suite 200, 1920 Yonge St., Toronto, Ontario, M4S 3E2, or by email to [email protected].

Sub-Processors

To support Approvalwise in delivering the Services, Approvalwise engages third-party service providers as sub-processors.

This page identifies our sub-processors, describes where they are located, lists the services they provide to us and identifies the type of Personal Information processed.

Our business needs may change from time to time and Approvalwise will periodically update this page to provide notice of additions and removals to our list of sub-processors.

Service Provider: Google

• Types of Personal Information processed: Details of how Google collects and processes data can be found here: Google Privacy & Terms
• Processor Activities: We use Google Analytics to collect analytics data for our web site to help us improve our Website. Google does not provide us with personal information about you but does allow us to view aggregate and non-identifiable information about how you (and other users) use the site so that we can make these improvements. Google may set their own cookies as part of providing this analytics capability.
• Locations: Various

Service Provider: Digital Ocean

• Types of Personal Information processed: Digital Ocean captures your IP address when you access our Website: Digital Ocean Data Processing Agreement
• Processor Activities: Captures IP addresses as part of Website logs which can be used for usage analytics and service support/debugging.
• Locations: Canada

Service Provider: Calendly

• Types of Personal Information processed: Calendly will collect your name and e-mail address when you schedule an appointment with us. Calendly’s policies around the collection and use of this data can be found here: Calendly Privacy Policy Notice
• Processor Activities: We use Calendly to manage scheduling of consultation appointments. A Calendly form in our web site allows you to book an appointment with us for a consultation. Calendly will ask you to provide your name and email address for this purpose and the email address will be used to communicate with you for the purpose of managing your appointment.
• Locations: Various

Service Provider: Atlassian

• Types of Personal Information processed: Atlassian provides a contact manager service we use. When you submit a contact form you are providing details to us via Jira Service Desk including your name, e-mail address and other details of your query. Atlassian captures and processes this data and sets cookies on your browser. Their policies around data collection and processing are here: Atlassian Privacy Policy
• Processor Activities: We use Jira Service Desk to provide a contact form on our web site so that users can contact us. This form sets a cookie (or cookies) on your browser. These are used for managing your session when creating and submitting a contact form.
• Locations: Various