PRIVACY NOTICE
Last updated February 24, 2022
This privacy notice for efosa Inc ("Company," "we," "us," or
"our"), describes how and why we might collect,
store, use, and/or share ("process") your
information when you use our services
("Services"), such as when you:
- Visit our website at http://www.efosa.ca, or any website of ours that links to this privacy notice
- Engage with us in other related ways ― including any sales, marketing, or events
Questions or concerns? Reading this
privacy notice will help you understand your privacy rights and
choices. If you do not agree with our policies and practices,
please do not use our Services. If you still have any questions
or concerns, please contact us at info@efosa.ca.
SUMMARY OF KEY POINTS
This summary provides key points from our privacy notice, but
you can find out more details about any of these topics by
clicking the link following each key point or by using our
table of contents below to find the section you are looking
for. You can also click here to go directly to our table of contents.
What personal information do we process? When
you visit, use, or navigate our Services, we may process personal
information depending on how you interact with efosa Inc and the
Services, the choices you make, and the products and features you
use. Click here to learn more.
Do we process any sensitive personal information?
We may process sensitive personal information when necessary with
your consent or as otherwise permitted by applicable law.
Click here to learn more.
Do you receive any information from third parties?
We may receive information from public databases, marketing
partners, social media platforms, and other outside sources.
Click here to learn more.
How do you process my information? We process
your information to provide, improve, and administer our Services,
communicate with you, for security and fraud prevention, and to
comply with law. We may also process your information for other
purposes with your consent. We process your information only when
we have a valid legal reason to do so. Click here to learn more.
In what situations and with which parties do we share personal
information?
We may share information in specific situations and with specific
third parties. Click here to learn more.
How do we keep your information safe? We have
organizational and technical processes and procedures in place to
protect your personal information. However, no electronic
transmission over the internet or information storage technology
can be guaranteed to be 100% secure, so we cannot promise or
guarantee that hackers, cybercriminals, or other unauthorized
third parties will not be able to defeat our security and
improperly collect, access, steal, or modify your information.
Click here to learn more.
What are your rights? Depending on where you are
located geographically, the applicable privacy law may mean you
have certain rights regarding your personal information.
Click here to learn more.
How do I exercise my rights? The easiest way to
exercise your rights is by filling out our data subject request
form available here, or by contacting us. We will consider and act upon any request
in accordance with applicable data protection laws.
Want to learn more about what efosa Inc does with any information
we collect? Click here to review the notice in full.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provide to
us.
We collect personal information that you voluntarily provide to
us when you register on the Services, express an interest in obtaining information about us or our
products and Services, when you participate in activities on
the Services, or otherwise when you contact us.
Personal Information Provided by You. The
personal information that we collect depends on the context of
your interactions with us and the Services, the choices you
make, and the products and features you use. The personal
information we collect may include the following:
- names
- phone numbers
- email addresses
- usernames
- passwords
- contact or authentication data
- mailing addresses
Sensitive Information. When necessary, with your
consent or as otherwise permitted by applicable law, we process
the following categories of sensitive information:
- information revealing race or ethnic origin
All personal information that you provide to us must be true,
complete, and accurate, and you must notify us of any changes to
such personal information.
Information collected from other sources
In Short: We may collect limited data from public databases,
marketing partners, and other outside sources.
In order to enhance our ability to provide relevant marketing,
offers, and services to you and update our records, we may
obtain information about you from other sources, such as public
databases, joint marketing partners, affiliate programs, data
providers, and
from other third parties. This information includes mailing
addresses, job titles, email addresses, phone numbers, intent
data (or user behavior data), Internet Protocol (IP) addresses,
social media profiles, social media URLs, and custom profiles,
for purposes of targeted advertising and event promotion.
2. HOW DO WE PROCESS YOUR INFORMATION?
In Short: We process your information to provide, improve, and
administer our Services, communicate with you, for
security and fraud prevention, and to comply with law.
We may also process your information for other
purposes with your consent.
We process your personal information for a variety of
reasons, depending on how you interact with our Services,
including:
- To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
- To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
- To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
- To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
- To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
- To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see "WHAT ARE YOUR PRIVACY RIGHTS?" below).
- To deliver targeted advertising to you. We may process your information to develop and display personalized content and advertising tailored to your interests, location, and more.
- To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
- To administer prize draws and competitions. We may process your information to administer prize draws and competitions.
- To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
- To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.
- To comply with our legal obligations. We may process your information to comply with our legal obligations, respond to legal requests, and exercise, establish, or defend our legal rights.
3. WHAT LEGAL BASES DO WE RELY ON TO
PROCESS YOUR INFORMATION?
In Short: We
only process your personal information
when we believe it is necessary and we
have a valid legal reason (i.e., legal
basis) to do so under applicable law,
like with your consent, to comply with
laws, to provide you with services to
enter into or fulfill our contractual
obligations, to protect your rights,
or to fulfill our legitimate business
interests.
If you are located in Canada,
this section applies to you.
We may process your information if you
have given us specific permission (i.e.,
express consent) to use your personal
information for a specific purpose, or
in situations where your permission can
be inferred (i.e., implied consent). You
can withdraw your consent at any time.
Click here to learn more.
In some exceptional cases, we may be
legally permitted under applicable law
to process your information without your
consent, including, for example:
- If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
- For investigations and fraud detection and prevention
- For business transactions provided certain conditions are met
- If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
- For identifying injured, ill, or deceased persons and communicating with next of kin
- If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
- If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
- If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
- If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
- If the collection is solely for journalistic, artistic, or literary purposes
- If the information is publicly available and is specified by the regulations
In Short: We may share information in
specific situations described in
this section and/or with the
following third parties.
We may need to share your personal
information in the following
situations:
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
In Short: We may use cookies
and other tracking
technologies to collect
and store your
information.
We may use cookies and
similar tracking
technologies (like web
beacons and pixels) to
access or store information.
Specific information about
how we use such technologies
and how you can refuse
certain cookies is set out
in our Cookie Notice.
6. HOW LONG DO WE
KEEP YOUR
INFORMATION?
In Short: We keep your information
for as long as necessary
to fulfill the purposes
outlined in this privacy
notice unless otherwise
required by law.
We will only keep your
personal information for as
long as it is necessary for
the purposes set out in this
privacy notice, unless a
longer retention period is
required or permitted by law
(such as tax, accounting, or
other legal requirements).
No purpose in this notice
will require us keeping your
personal information for
longer than the period of
time in which users have an
account with us.
When we have no ongoing
legitimate business need to
process your personal
information, we will either
delete or anonymize such
information, or, if this is
not possible (for example,
because your personal
information has been stored
in backup archives), then we
will securely store your
personal information and
isolate it from any further
processing until deletion is
possible.
7. HOW DO WE KEEP
YOUR INFORMATION
SAFE?
In Short: We aim to protect your
personal information
through a system of
organizational and
technical security
measures.
We have implemented
appropriate and reasonable
technical and organizational
security measures designed
to protect the security of
any personal information we
process. However, despite
our safeguards and efforts
to secure your information,
no electronic transmission
over the Internet or
information storage
technology can be guaranteed
to be 100% secure, so we
cannot promise or guarantee
that hackers,
cybercriminals, or other
unauthorized third parties
will not be able to defeat
our security and improperly
collect, access, steal, or
modify your information.
Although we will do our best
to protect your personal
information, transmission of
personal information to and
from our Services is at your
own risk. You should only
access the Services within a
secure environment.
8. WHAT ARE YOUR
PRIVACY
RIGHTS?
In Short: In some regions,
such as Canada, you have
rights that allow you
greater access to and
control over your personal
information. You may review, change,
or terminate your account
at any time.
In some regions (like
Canada), you have certain
rights under applicable data
protection laws. These may
include the right (i) to
request access and obtain a
copy of your personal
information, (ii) to request
rectification or erasure;
(iii) to restrict the
processing of your personal
information; and (iv) if
applicable, to data
portability. In certain
circumstances, you may also
have the right to object to
the processing of your
personal information. You
can make such a request by
contacting us by using the
contact details provided in
the section “HOW CAN YOU CONTACT US
ABOUT THIS NOTICE?” below.
We will consider and act
upon any request in
accordance with applicable
data protection laws.
If you are located in the
EEA or UK and you believe we
are unlawfully processing
your personal information,
you also have the right to
complain to your local data
protection supervisory
authority. You can find
their contact details here:
https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you are located in
Switzerland, the contact
details for the data
protection authorities are
available here:
https://www.edoeb.admin.ch/edoeb/en/home.html.
Withdrawing your
consent:
If we are relying on your
consent to process your
personal information, which
may be express and/or
implied consent depending on
the applicable law, you have
the right to withdraw your
consent at any time. You can
withdraw your consent at any
time by contacting us by
using the contact details
provided in the section
"HOW CAN YOU CONTACT US
ABOUT THIS NOTICE?" below.
However, please note that
this will not affect the
lawfulness of the processing
before its withdrawal, nor
when applicable law allows,
will it affect the processing
of your personal information
conducted in reliance on
lawful processing grounds
other than consent.
Opting out of marketing
and promotional
communications: You can unsubscribe from our
marketing and promotional
communications at any time by
clicking on the unsubscribe
link in the emails that we
send, or by contacting us
using the details provided in
the section "HOW CAN YOU CONTACT US
ABOUT THIS NOTICE?" below. You will then be
removed from the marketing
lists — however, we may still
communicate with you, for
example to send you
service-related messages that
are necessary for the
administration and use of your
account, to respond to service
requests, or for other
non-marketing purposes.
Account Information
If you would at any time like
to review or change the
information in your account or
terminate your account, you
can:
- Log in to your account settings and update your user account.
- Contact us using the contact information provided.
Upon your request to
terminate your account, we
will deactivate or delete your
account and information from
our active databases. However,
we may retain some information
in our files to prevent fraud,
troubleshoot problems, assist
with any investigations,
enforce our legal terms and/or
comply with applicable legal
requirements.
Cookies and similar
technologies:
Most Web browsers are set to
accept cookies by default.
If you prefer, you can
usually choose to set your
browser to remove cookies
and to reject cookies. If
you choose to remove cookies
or reject cookies, this
could affect certain
features or services of our
Services. To opt out of
interest-based advertising
by advertisers on our
Services visit
http://www.aboutads.info/choices/.
If you have questions or
comments about your privacy
rights, you may email us at
policies@efosa.ca.
9. CONTROLS FOR
DO-NOT-TRACK
FEATURES
Most web browsers and some
mobile operating systems and
mobile applications include
a Do-Not-Track ("DNT")
feature or setting you can
activate to signal your
privacy preference not to
have data about your online
browsing activities
monitored and collected. At
this stage no uniform
technology standard for
recognizing and implementing
DNT signals has been
finalized. As such, we do
not currently respond to DNT
browser signals or any other
mechanism that automatically
communicates your choice not
to be tracked online. If a
standard for online tracking
is adopted that we must
follow in the future, we
will inform you about that
practice in a revised
version of this privacy
notice.
10. DO CALIFORNIA
RESIDENTS HAVE
SPECIFIC PRIVACY
RIGHTS?
In Short: Yes, if you are a
resident of California,
you are granted specific
rights regarding access to
your personal
information.
California Civil Code
Section 1798.83, also known
as the "Shine The Light"
law, permits our users who
are California residents to
request and obtain from us,
once a year and free of
charge, information about
categories of personal
information (if any) we
disclosed to third parties
for direct marketing
purposes and the names and
addresses of all third
parties with which we shared
personal information in the
immediately preceding
calendar year. If you are a
California resident and
would like to make such a
request, please submit your
request in writing to us
using the contact
information provided
below.
If you are under 18 years
of age, reside in
California, and have a
registered account with
Services, you have the right
to request removal of
unwanted data that you
publicly post on the
Services. To request removal
of such data, please contact
us using the contact
information provided below
and include the email
address associated with your
account and a statement that
you reside in California. We
will make sure the data is
not publicly displayed on
the Services, but please be
aware that the data may not
be completely or
comprehensively removed from
all our systems (e.g.,
backups, etc.).
CCPA Privacy Notice
The California Code
of Regulations
defines a "resident"
as:
(1) every individual who is
in the State of California
for other than a temporary
or transitory purpose
and
(2) every individual who is
domiciled in the State of
California who is outside
the State of California for
a temporary or transitory
purpose
All other individuals are
defined as
"non-residents."
If this definition of
"resident" applies to you,
we must adhere to certain
rights and obligations
regarding your personal
information.
What categories of
personal information do we
collect?
We have collected the
following categories of
personal information in the
past twelve (12)
months:
| Category | Examples | Collected |
A.
Identifiers | Contact details,
such as real name,
alias, postal
address, telephone
or mobile contact
number, unique
personal identifier,
online identifier,
Internet Protocol
address, email
address, and account
name | YES |
B. Personal
information
categories listed in
the California
Customer Records
statute | Name, contact
information,
education,
employment,
employment history,
and financial
information | YES |
C. Protected
classification
characteristics
under California or
federal law | Gender and date of
birth | YES |
D. Commercial
information | Transaction
information,
purchase history,
financial details,
and payment
information | NO |
E. Biometric
information | Fingerprints and
voiceprints | NO |
F. Internet or
other similar
network
activity | Browsing history,
search history,
online behavior,
interest data, and
interactions with
our and other
websites,
applications,
systems, and
advertisements | NO |
G. Geolocation
data | Device
location | NO |
H. Audio,
electronic, visual,
thermal, olfactory,
or similar
information | Images and audio,
video or call
recordings created
in connection with
our business
activities | NO |
I. Professional or
employment-related
information | Business contact
details in order to
provide you our
services at a
business level or
job title, work
history, and
professional
qualifications if
you apply for a job
with us | NO |
J. Education
Information | Student records and
directory
information | NO |
K. Inferences drawn
from other personal
information | Inferences drawn
from any of the
collected personal
information listed
above to create a
profile or summary
about, for example,
an individual’s
preferences and
characteristics | NO |
We may also collect other
personal information outside
of these categories
instances where you interact
with us in person, online,
or by phone or mail in the
context of:
- Receiving help through our customer support channels;
- Participation in customer surveys or contests; and
- Facilitation in the delivery of our Services and to respond to your inquiries.
How do we use and share
your personal
information?
More information about our data
collection and sharing practices
can be found in this privacy
notice.
You may contact us
by email at
policies@efosa.ca, or by referring to the contact
details at the bottom of this
document.
If you are using an
authorized agent to exercise
your right to opt out we may
deny a request if the
authorized agent does not
submit proof that they have
been validly authorized to
act on your behalf.
Will your information be
shared with anyone
else?
We may disclose your
personal information with
our service providers
pursuant to a written
contract between us and each
service provider. Each
service provider is a
for-profit entity that
processes the information on
our behalf.
We may use your personal
information for our own
business purposes, such as
for undertaking internal
research for technological
development and
demonstration. This is not
considered to be "selling"
of your personal
information.
efosa Inc has not disclosed or
sold any personal
information to third parties
for a business or commercial
purpose in the preceding
twelve (12) months.
efosa Inc will not sell personal
information in the future
belonging to website
visitors, users, and other
consumers.
Your rights with respect
to your personal
data
Right to request deletion
of the data — Request to
delete
You can ask for the
deletion of your personal
information. If you ask us
to delete your personal
information, we will respect
your request and delete your
personal information,
subject to certain
exceptions provided by law,
such as (but not limited to)
the exercise by another
consumer of his or her right
to free speech, our
compliance requirements
resulting from a legal
obligation, or any
processing that may be
required to protect against
illegal activities.
Right to be informed —
Request to know
Depending on the
circumstances, you have a
right to know:
- whether we collect and use your personal information;
- the categories of personal information that we collect;
- the purposes for which the collected personal information is used;
- whether we sell your personal information to third parties;
- the categories of personal information that we sold or disclosed for a business purpose;
- the categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
- the business or commercial purpose for collecting or selling personal information.
In accordance with
applicable law, we are not
obligated to provide or
delete consumer information
that is de-identified in
response to a consumer
request or to re-identify
individual data to verify a
consumer request.
Right to
Non-Discrimination for the
Exercise of a Consumer’s
Privacy Rights
We will not discriminate
against you if you exercise
your privacy rights.
Verification process
Upon receiving your
request, we will need to
verify your identity to
determine you are the same
person about whom we have
the information in our
system. These verification
efforts require us to ask
you to provide information
so that we can match it with
information you have
previously provided us. For
instance, depending on the
type of request you submit,
we may ask you to provide
certain information so that
we can match the information
you provide with the
information we already have
on file, or we may contact
you through a communication
method (e.g., phone or
email) that you have
previously provided to us.
We may also use other
verification methods as the
circumstances dictate.
We will only use personal
information provided in your
request to verify your
identity or authority to
make the request. To the
extent possible, we will
avoid requesting additional
information from you for the
purposes of verification.
However, if we cannot verify
your identity from the
information already
maintained by us, we may
request that you provide
additional information for
the purposes of verifying
your identity and for
security or fraud-prevention
purposes. We will delete
such additionally provided
information as soon as we
finish verifying you.
Other privacy rights
- You may object to the processing of your personal information.
- You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information.
- You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
- You may request to opt out from future selling of your personal information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission.
To exercise these rights,
you can contact
us by email at
policies@efosa.ca, or by referring to the contact
details at the bottom of this
document. If you have a
complaint about how we handle
your data, we would like to hear
from you.
11. DO WE MAKE
UPDATES TO THIS
NOTICE?
In Short: Yes, we will update this
notice as necessary to
stay compliant with
relevant laws.
We may update this privacy
notice from time to time.
The updated version will be
indicated by an updated
"Revised" date and the
updated version will be
effective as soon as it is
accessible. If we make
material changes to this
privacy notice, we may
notify you either by
prominently posting a notice
of such changes or by
directly sending you a
notification. We encourage
you to review this privacy
notice frequently to be
informed of how we are
protecting your
information.
12. HOW CAN YOU
CONTACT US ABOUT
THIS NOTICE?
If you have questions or
comments about this notice,
you may
email us at
policies@efosa.ca or by post
to:
efosa Inc
__________
__________
13. HOW CAN YOU
REVIEW, UPDATE, OR
DELETE THE DATA WE
COLLECT FROM
YOU?
Based on the applicable
laws of your country, you
may have the right to
request access to the
personal information we
collect from you, change
that information, or delete
it in some circumstances. To
request to review, update,
or delete your personal
information, please submit a
request form by
clicking here.
