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Privacy Policy

Afflo is committed to respecting and protecting your privacy. This privacy notice sets out how we look after your personal data when you visit our website at afflo.io, and tells you about your privacy rights and how certain laws may apply to you. If you have any queries about this policy or how we use your personal information, please contact us at privacy@shore.ca

Your privacy is important to us. To protect your privacy and help you to make informed choices, we provide this notice explaining our information practices, how you can choose how we use your data, and your rights in relation to your data. In brief, we will only use your information:

  • to enable us to deliver our website services to you;
  • where you have consented to us doing so;
  • where it is in our legitimate interests to do so and such interests are not overridden by your personal data rights.
  • This is explained in more detail below.
How and why we use personal data

We will only use your information where:

A. Personal data you provide to us

When you sign up to one of our mailing lists, you will provide us with your identity, contact information, IP address, and your marketing and communications preferences. This data is collected via direct solicitation as well as by the use of email tracking codes embedded in our marketing emails. We do not embed tracking codes in our regular daily email correspondence.

We may ask you to provide information about yourself and/or your organization. We may also ask about your and/or your organization’s business needs, priorities and concerns.

You will also provide us with personal data when you correspond with us, and if you apply for a position with the firm.

B. Personal data we collect automatically

As you use the site, we will collect certain technical data including your browser type, the Internet Protocol (IP) address used to connect your computer to the internet, and your usage habits, patterns and preferences. We collect this data using cookies, beacons and similar technologies. We use Google Analytics to help us analyze user habits while visiting our site. The data gathered from cookies may be transmitted to Google servers in the United States. We employ IP address anonymization to ensure that there is no direct reporting of individual user IPs as part of this process. The information will be used by Google only for the purpose of evaluating website use, creating website activity reports, and other services relating to website activity and internet usage on behalf of Afflo. The IP address that your browser conveys within the scope of Google Analytics, will not be associated with any other data held by Google.

You can remove cookies from your computer through the settings on your browser, but be aware that this may impact your ability to make use of some features on this and other web sites. Management of cookie settings varies from one browser to another. The “Help” menu of your web browser will provide full instructions.

Information to keep our records up to date.

We will use your technical information to:

  • provide and make improvements to the site, system maintenance, support, reporting and hosting of data, and troubleshooting;
  • ensure that the site is secure;
  • analyze how users interact with the site; and
  • address any issues you may experience with the site.

We may also use any or all of the information above to administer and manage our business in general. If you feel that your interests and fundamental rights outweigh our business purposes, and that we should therefore stop processing your data, please let us know.

C. We need to comply with a legal or regulatory obligation

In certain circumstances, we may need to retain or use your data to comply with regulations and/or the law. This includes ensuring we do not have any conflicts of interest or any other regulatory restrictions which would prevent us from providing you with advice.

How we share personal data

We may share your information with our trusted third party service providers (including information technology providers such as website and mailing list hosts for the purposes outlined in this policy and only in accordance with applicable law). When we share your information with our service providers, we will ensure that your data is kept secure and used only in accordance with this notice.

On rare occasions, we may share personal data when we believe it is necessary to comply with the law, regulation or legal request (including a court order or government inquiry); to enforce or apply our terms of use or other agreements; or to protect the rights, property, or safety of the firm, our employees, our users, or others.

This site may contain links to other sites whose information practices may be different than ours. Please consult all third party sites’ privacy notices as we have no control over information that is submitted to, or collected by, third parties.

How long we keep personal data

We will only retain your personal data 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.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Data security

The safety of your personal data is important to us, and we use various technical and organization measures to ensure that your data is secure.

We take the security of your personal information very seriously and are committed to protecting your privacy by using a combination of administrative, physical, and technical safeguards. These measures include multi-factor authentication, masking, encryption, logging and monitoring, described below. We store your personal information for as long as it is necessary to provide you with our programs, products, and services and for a reasonable time thereafter, or as permitted or required by law.

However, the transmission of information via the Internet is not completely secure. Although we take appropriate measures to safeguard against unauthorized disclosures of information, we cannot guarantee the security of your data.

Changes to this policy or your data

We may amend or modify this privacy notice from time to time. We will post any revised notice on this site. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Your rights

Under applicable privacy law, you have the right to access the personal information we hold about you, subject to any legal restrictions. Upon request, we will provide you with access to your personal information within a reasonable timeframe, in compliance with applicable laws.

It is your responsibility to provide accurate, correct and complete information. If you notice any errors in your personal information or need to update it, please let us know through the steps outlined below. You can email us at privacy@afflo.io to request access to your personal information.

If you are unsatisfied with our response to your access and/or correction request, or how we handle your personal information, please contact the appropriate Privacy Office. If the Privacy Office is unable to address your concern to your satisfaction, you may bring the matter to the attention of the appropriate Privacy Commissioner.

Changes

We may make changes to this policy from time to time. Any changes we make will become effective when we post a modified version of the policy on this webpage. If we make any significant changes to the policy, we will post a notice on our websites. By continuing to participate in our programs, and/or use our services after the modified version of the policy has been posted, you are accepting the changes to the policy, subject to any additional requirements which may apply. If you do not agree to the changes in our policy, it is your responsibility to stop participating in our programs, and/or using our services or purchasing our products. It is your obligation to ensure that you read, understand and agree to the latest version of the policy. The “Effective Date” at the top of the policy indicates when it was last updated.

Who do I contact with privacy questions?

We have appointed a dedicated Privacy Officer responsible for overseeing our privacy program and ensuring compliance with applicable privacy laws and regulations. If you have any questions about how we handle your personal information, please contact privacy@shore.ca

Last updated 16 January 2023