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OUR COMMITMENT TO YOUR PRIVACY

Our Privacy Policy tells you what Personally Identifiable Information (“PII”) Elite Digital Inc. (“Elite”) may collect from you, how we handle your PII, and how you can limit our sharing of your PII.

Elite is committed to the security and privacy of all our clients and people we engage. We take your privacy seriously, and we will work with you to ensure that you have an enjoyable experience that ensures your information is safe.

Elite respects your privacy and recognizes the need for appropriate protection and management of any information that is shared with us.

All PII related information that Elite may collect about you on our Websites that we maintain in our control are protected with the highest levels of encryption (i.e. AES256) to ensure that maximum safeguards are in place to protect your data.

General Guidelines

The purpose of this policy is to outline the acceptable use, collection and handling of personal information. This policy closely abides by and complements the standards set forth in the Personal Information Protection and Electronic Documents Act (PIPEDA).

In order to remain compliant to applicable standards, policies and governing laws, any reference to Personally Identifiable Information or PII, will henceforth, unless otherwise mentioned, refer to the use and management of PII in a digital format only. Any stakeholders that may come in contact and/or receive PII in a non-digital based format (i.e. paper) must immediately destroy all copies via appropriate secure shredding and/or waste management. Use and/or handling of PII in non-digital formats are strictly forbidden.

All stakeholders may be permitted limited time-restricted use rights to PII provided that such data is accessed from company-owned and/or client approved managed system(s). Under no circumstances shall PII be copied and/or distributed for any other reason but for the sole use of conducting business under such contracted and/or consented use rights.

All system(s) that access, store, and/or use PII must and shall remain encrypted at all times, both at rest, and in transit over secure channels. All communication and encryption standards that contain PII must support a minimum standard(s) of TLS1.2 and AES256 encryption. No person(s), and/or device(s), shall have and/or use PII without consent from applicable senior leadership and/or client designated stakeholders. All devices permitted to use PII, at a minimum, must comply with Elite’s Acceptable Use and Asset Management policies, specifically, supporting the use of disk encryption, virus/malware and ransomware protection and multi-factor authentication. Use of PII may not be copied for use in local databases, web/application servers, audio/video conferencing, chat, screen sharing and/or other remote control solutions (not used by local IT administration) and is strictly forbidden.

All copies of PII in accordance with this and/or other applicable policies must upon completion of such activities be immediately destroyed through secure processes (i.e. secure waste removal).

Under no circumstances will BYOD or other personal devices be acceptable or permitted to access or use PII.

Website

DEFINITIONS

"Non-Personal Information" (NPI) is information that is in no way personally identifiable and that is obtained automatically when you access our Website or Websites we build for clients with a web browser. "Personally Identifiable Information" (PII) is non-public information that is personally identifiable to you and obtained for us to provide you with a service.

“Personal Identifiable Information” (PII) refers to information that is provided to, or exchanged with us that may contain sensitive information about you. PII may include information such as your name, address, phone number, payment information, or other pertinent information about you.

GDPR

The General Data Protection Regulation (GDPR) is the most significant legislative change in European data protection laws since the EU Data Protection Directive (Directive 95/46/EC), introduced in 1995. The GDPR became enforceable on May 25, 2018, strengthens the security and protection of personal data in the EU and serves as a single piece of legislation for all of the EU. It replaced the EU Data Protection Directive and all the local laws relating to it.

Elite supports the GDPR and complies with its provisions. Not only is the GDPR an important step in protecting the fundamental right of privacy for European citizens, it has raised the bar for data protection, security and compliance in the industry.

OTHER WEBSITES

Our Website may contain links to other Websites. You understand that these Websites are not under our control and are not subject to our Privacy Policy. These Websites will likely have their own privacy policies. We have no responsibility for these Websites and provide links to these Websites solely for your convenience. Furthermore, and for greater clarity, data that we collect on digital properties that have been created for our clients will result in the data belonging to that client and will be governed by their policies. Simply seeing our name as the creator of a project does not imply it is our policies that are in effect. Please be sure to look for the privacy policy or a link to the client’s privacy policy on the specific Website you are interacting with.

Our service sometimes includes hosting customers' web sites that were built using various content management systems (such as Wordpress) that are under their control. Elite is not responsible for posting and/or enforcing our customers' privacy policies. While we are in no way responsible or liable for the collection and use of personal information by our customers from their Web sites or during application of our marketing services, we will make every reasonable effort to ensure that our customers post and enforce their privacy policies.

You acknowledge that your use and access of these other Websites is solely at your own risk. It is your responsibility to check the privacy policies of these other Websites to see how they treat your personal information.

INFORMATION WE COLLECT

When you engage us, the information we collect can vary depending on your point of engagement. The information typically, but not exclusively, is related to one of the following categories:

  1. Personal Contact Information
  2. Topics/products of interest
  3. Industry Information
  4. Company Information
  5. Payment Information
  6. Demographic Information
  7. Information About Your Transactions With Us

Generally, you control the amount and type of information you provide to us when using our Website. As a visitor to our Website, you can browse our Website to find out more about us. You are not required to provide us with any PII as a Visitor.

We offer you choices when we ask for personal information, whenever reasonably possible. You may decline to provide PII to us in our registration/contact forms and/or refuse cookies in your browser, although some of our features or services may not function properly as a result. We make good faith efforts to provide you access to your personal information upon request with proper validation and to let you correct such data if it is inaccurate and delete it, when reasonably possible.

Personal Data we collect or receive may be stored and processed in Canada or the United States or any other country where we or our service providers have facilities.

COMPUTER INFORMATION COLLECTED

When you use our Website, we automatically collect certain computer information by the interaction of your web browser with our Website. Such information is typically considered NPI. We may also collect and/or serve a “cookie”.

A Cookie is a small piece of data stored on your computer/device by your web browser. We use Cookies to identify the areas of our Website that you have visited. We also use cookies and other technologies to enhance your online experience. Finally, we may use Cookies to personalize the Content that you see on our Website. Most web browsers can be set to disable the use of Cookies. However, if you disable Cookies, you may not be able to access features on our Website correctly or at all. We never place PII in Cookies.

In the interest of providing our visitors and clients with an optimal experience, our servers automatically record information when you visit our Website, including the URL, IP address, browser type and language, along with the date and time of your request. We use all of this information to analyze trends among our users to help improve our Website and services.

GOOGLE ANALYTICS

Our Website uses “Google Analytics” to collect information about the use of our site. Google Analytics collects information such as how often users visit our site, what pages they visit when they do so, and what other sites they used prior to coming to our site. We use the information we get from Google Analytics to improve our site and enhance our services.

Google Analytics collects only the IP address assigned to you on the date you visit our site, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Although Google Analytics plants a permanent cookie on your web browser to identify you as a repeat visitor the next time you visit our site, the cookie cannot be used by anyone but Google.

Google’s ability to use and share information collected by Google Analytics about your visits to our site is restricted by the Google Analytics Terms of Use. http://www.google.com/analytics/terms/us.html

You can prevent Google Analytics from recognizing you on return visits to this site by disabling cookies on your browser. https://tools.google.com/dlpage/gaoptout

HOW INFORMATION IS USED

We use the information we receive from you when providing requested services and answering any questions you may ask.

We may use PII to provide marketing or other services you've requested, including communicating with you about program information, technical issues, project updates, industry information, policy changes and other information of interest to you. We may also use PII for auditing, research and analysis to operate and improve our marketing technologies and services.

Any time we use your PII, it is done so with the utmost attention to care, sensitivity, privacy and security.

We retain and store your Personal Data only for as long as we have a legitimate business purpose and in accordance with our data retention policies.

COMMUNICATIONS BY EMAIL OR TEXT

When we communicate with you about our potential or active services, we will use the email address or addresses you provided to us. We know your inbox is important to you and we will always be mindful about the emails we send.

In order to achieve the goals of the anti-spam legislation, Elite will ensure to act in compliance with Canada’s Anti-Spam Legislation (CASL). In order to ensure compliance, commercial electronic messages (including transactional and mass emails) will be based on an “opt-In” approach. Elite will gain consent for commercial electronic messages purposes prior to sending commercial messages, unless we have a pre-existing business relationship with a client or potential client as in these particular cases consent is considered to be implied. Individuals that “opt-out” from receiving emails from Elite will be blocked upon the swift processing of the request.

This is in accordance with Canada’s Anti-Spam Law (CASL), effective July 1, 2014.

SHARING INFORMATION

We do NOT sell, rent, or otherwise provide your PII to third parties for marketing purposes. We also do not under any circumstances share data between clients.

LEGALLY REQUIRED RELEASES OF INFORMATION

We may be legally required to disclose your PII, if such disclosure is (a) required by subpoena, law, or other legal process; (b) necessary to assist law enforcement officials or government enforcement agencies; (c) necessary to investigate violations of or otherwise enforce our Legal Terms; (d) necessary to protect us from legal action or claims from third parties including you and/or other Members; and/or (e) necessary to protect the legal rights, personal/real property, or personal safety of our company, our Users, employees, and affiliates.

DISCLOSURES OF SUCCESSORS

If our business is acquired or merges, in whole or in part, with another business that would become responsible for providing services to you, we retain the right to transfer your PII to the new business. The new business would retain the right to use your PII according to the terms of this Privacy Policy as well as to any changes to this Privacy Policy as instituted by the new business.

CHILDREN'S POLICY

Our service does not address anyone under the age of 13 (“Children”).

We do not knowingly collect personally identifiable information from children under 13. If you are a parent or guardian and you are aware that your child/children have provided us with Personal Information, please contact us. If we discover that a child under 13 has provided us with Personal Information, we will delete such information from our servers immediately unless it is a legal requirement that the information be retained.

OUR SECURITY POLICY

We have taken steps to build our Website and internal infrastructure using sophisticated encryption based on AES256 standards, processes and authentication tools to protect the security of your PII and any other information we may collect on behalf of our clients. We use industry standard technologies such as secure routers and firewalls to make sure that your PII is safe, in addition to network monitoring tools to detect for any unusual behavior or possible intrusion attempts. We have strict data access and storage policies in place across our entire organization.

LIMITATION OF LIABILITY

You assume the sole risk of transmitting your information as it relates to the use of this Website. In no event shall Elite be liable for any direct, indirect, special, consequential or monetary damages, including fees, and penalties in connection with your use of materials posted on this or connectivity to or from this Website to any other Website.

CHANGES TO OUR PRIVACY POLICY

We reserve the right to change this privacy policy at any time. If our company decides to change this Privacy Policy, we will post those changes on our Website so our visitors and clients are always aware of what information we collect, use, and disclose. If at any time we decide to disclose or use your personally identifiable information in a method different from that specified at the time it was collected, we will provide advance notice by email or other communication methods. Otherwise, we will use and disclose personally identifiable information in agreement with the Privacy Policy that was in effect, when that information was collected. In all cases, your continued use of our Website or our services and products after any changes to this Privacy Policy will constitute your acceptance of such change.

Contact

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact privacy@elitedigital.ca or by mail using the details provided below:

Elite Digital Inc.
5511 Steeles Ave. West
Suite 200
Toronto, Ontario, Canada
M9L 1S7

Email: privacy@elitedigital.ca