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Privacy Policy

At Informal, we are committed to protecting and respecting your privacy. This Policy explains when and why we may collect personal information about people who visit our website and utilize our services, how we use it, the conditions under which we may disclose it to others, and how we keep it secure. This Policy also explains how we use cookies and similar technology on our website(s).

We may change this policy from time to time at our discretion so please check this page occasionally to ensure that you are satisfied with any changes. By accessing our website or otherwise using our services, you are agreeing to be bound by this Policy.

This Website collects some Personal Data from its Users.

Users may be subject to different protection standards and broader standards may therefore apply to some. 

Owner and Data Controller

Informal Systems Inc. 180 John Street Toronto, ON, Canada M5T 1X5

Owner contact email: hello@informal.systems

Types of Data collected

Among the types of Personal Data that this Website collects, by itself or through third parties, are: email address; first name; last name; Data communicated while using the service, including aggregate information or data volunteered by the user; Usage Data, including information related to your use of the site and the services, including IP address, geographic location, and date and time of your request; Trackers.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.

Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Website.

Unless specified otherwise, all Data requested by this Website is mandatory and failure to provide this Data may make it impossible for this Website to provide its services. In cases where this Website specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.

Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.

Any use of Cookies -- or of other tracking tools -- by this Website or by the owners of third-party services used by this Website serves the purpose of providing the Service required by the User, in addition to any other purposes described in this privacy policy.

Users are responsible for any third-party Personal Data obtained, published or shared through this Website and confirm that they have the third party's consent to provide the Data to the Owner.

Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data. The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Website (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

  • Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing ("opt-out"), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;

  • provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;

  • processing is necessary for compliance with a legal obligation to which the Owner is subject;

  • processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;

  • processing is necessary for the purposes of the legitimate business interests pursued by the Owner or by a third party, such as: (a) to provide the information or content you have requested, (b) to contact you about our programs, products, features or services, (c) for internal business purposes such as identification and authentication or customer service, (d) to ensure the security of our website, by trying to prevent unauthorized or malicious activities, (e) to enforce compliance with our terms of use and other policies, (f) to help other organizations (such as copyright owners) to enforce their rights.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place

The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located. Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

If broader protection standards are applicable, Users are also entitled to learn about the legal basis of Data transfers to a country, for example,  outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data. If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

  • Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.

  • Personal Data collected for the purposes of the Owner's legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority. Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

Sharing Information

We do not share or sell your personal data to other organizations for commercial purposes, except to provide products or services you have requested, when we have your permission, or under the following circumstances:

  • It is necessary to share information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of Terms of Service, or as otherwise required by law.

  • We transfer information about you if Informal is acquired by or merged with another company. In this event, Informal will notify you before information about you is transferred and becomes subject to a different privacy policy.

  • We provide such information to trusted businesses or persons for the sole purpose of processing personally identifying information on our behalf. When this is done, it is subject to agreements that oblige those parties to process such information only on our instructions and in compliance with this Privacy Policy and appropriate confidentiality and security measures.

  • We provide such information to third parties who have entered into non-disclosure agreements with us.

  • We provide such information to a company controlled by, or under common control with, Informal for any purpose permitted by this Privacy Policy.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Managing contacts and sending messages, Interaction with data collection platforms and other third parties, Hosting and backend infrastructure, Displaying content from external platforms, Analytics and Interaction with external social networks and platforms.

For specific information about the Personal Data used for each purpose, the User may refer to the section "Detailed information on the processing of Personal Data".

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

  • Analytics

  • Displaying content from external platforms

  • Hosting and backend infrastructure

  • Interaction with data collection platforms and other third parties

  • Interaction with external social networks and platforms

  • Managing contacts and sending messages

The rights of Users

Users may exercise certain rights regarding their Data processed by the Owner.

Users entitled to broader protection standards may exercise any of the rights described below. In all other cases, Users may inquire with the Owner to find out which rights may apply to them.

In particular, Users have the right to do the following:

  • Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.

  • Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.

  • Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.

  • Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.

  • Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.

  • Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.

  • Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.

  • Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

Data Storage

Informal uses third party vendors and hosting partners to provide the necessary hardware, software, networking, storage, and related technology required to run Informal and related products. Informal owns the code, databases, and all rights to the Informal applications.

Security

We take precautions to ensure the security of your personal information. However, we cannot guarantee that hackers or unauthorized personnel may not gain access to your personal information despite our efforts. You should note that in using the Informal services, your information will travel over the Internet and through third party infrastructures which are not under our control.

We cannot protect, nor does this Privacy Policy apply to, any information that you transmit to other users. You should never transmit personal or identifying information to other users.

Majority

The Informal services and products are not intended for minors, and we do not knowingly collect information from minors. Per our terms of use, minors are expressly prohibited from utilizing the Informal services.

Applicability of broader protection standards

While most provisions of this document concern all Users, some provisions expressly only apply if the processing of Personal Data is subject to broader protection standards.

Such broader protection standards apply when the processing:

  • is performed by an Owner based within the EU;

  • concerns the Personal Data of Users who are in the EU and is related to the offering of paid or unpaid goods or services, to such Users;

  • concerns the Personal Data of Users who are in the EU and allows the Owner to monitor such Users' behavior taking place in the EU.

Cookies and Web Beacons

A COOKIE IS A SMALL AMOUNT OF DATA, WHICH OFTEN INCLUDES AN ANONYMOUS UNIQUE IDENTIFIER, WHICH IS SENT TO YOUR BROWSER FROM A WEBSITE'S COMPUTERS AND STORED ON YOUR COMPUTER'S HARD DRIVE. COOKIES ARE REQUIRED TO USE SOME INFORMAL SERVICES. INFORMAL USES COOKIES TO RECORD CURRENT SESSION INFORMATION.

WITH COOKIES, THE INFORMATION THAT WE COLLECT AND SHARE IS ANONYMOUS AND NOT PERSONALLY IDENTIFIABLE. IT DOES NOT CONTAIN YOUR NAME, ADDRESS, TELEPHONE NUMBER, OR EMAIL ADDRESS.

YOU CAN OPT-OUT OF GOOGLE ANALYTICS DATA COLLECTION WITH THE GOOGLE ANALYTICS OPT-OUT BROWSER ADD-ON.

YOU MAY ALSO WISH TO REFER TO THIS WEBSITE FOR ADDITIONAL INFORMATION ABOUT DISABLING COOKIES FROM YOUR BROWSER: HTTP://WWW.ALLABOUTCOOKIES.ORG/MANAGE-COOKIES/.

Additional information about Data collection and processing

Legal action

The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Website or the related Services. The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data

In addition to the information contained in this privacy policy, this Website may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, this Website and any third-party services may collect files that record interaction with this Website (System logs) or use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

How "Do Not Track" requests are handled

This Website does not support "Do Not Track" requests. To determine whether any of the third-party services it uses honor the "Do Not Track" requests, please read their privacy policies.