Privacy Policy for Client Personal Information
Effective October 2, 2018
Calmillar.com is committed to protecting the privacy and security of every client’s personal information obtained by reason of your client relationship with us. This policy explains the types of client personal information we collect, how it is used, and the steps we take to ensure your personal information is handled appropriately.
Our policies and practices have been designed to comply with the Personal Information Protection and Electronic Documents Act (PIPEDA), corresponding provincial privacy acts and GDPR Privacy Policy.
What is personal information?
Personal information is information that refers to an individual specifically and is recorded in any form. Personal information includes such things as age, income, date of birth, ethnic origin, medical records and credit records. Information about individuals contained in the following documents is not considered personal information:
- public telephone directories, where the subscriber can refuse to be listed,
- professional and business directories available to the public,
- certain public registries and court records,
- certain other publicly available printed and electronic publications.
Our commitment to your privacy is governed by the following privacy principles:
- Introduction
- About Us
- Collection of Information
- Our Legal Bases for Using Personal Information
- How We User Personal Information
- How We Share Your Information
- Access & Control of Your Information
- Retention of Personal Information
- Cookies and Similar Technologies
- What Cookies Do We Use and Why?
- How We Use Cookies and Similar Technologies
- Managing Cookies
- Changes to This Policy
- Contact Us
Introduction
This Privacy and Cookie Policy explains how we collect, use, share, disclose or otherwise process personal information we hold about you. Understanding what our audiences prefer allows us to personalize content, and generally improve your experience of our products and services.
About Us
Calmillar.com will collect, use, share and disclose or otherwise process your personal information in line with this Policy.
Collection of information
We collect information about you when you fill in a contact form or email us directly. We also collect information when you voluntarily comment on our blog posts, provide feedback and participate in competitions. Website usage information is collected using cookies.
The information we collect about you may include; your name, email address, address, phone number, IP address, location, company name, sex, age, your chosen internet browser and service provider, and device plus any information you supply voluntarily.
Our Legal Bases for Using Personal Information
We collect information about you to:
- Fulfill your request – For example, if you fill out a “request more information” form we use this information to contact you directly,
- Process your order,
- Manage your account,
- And, if you agree, to email you about other products, services, and information we think may be of interest to you.
We may use your contact information to advertise our service to you on third-party websites such as Facebook and Twitter. We may also contact you directly to follow up on the service and user experience we provide.
We use your information collected from the website to personalize your repeat visits to our website. If you agree, we shall pass on your personal information to third parties so that they may offer you their products and services.
All organizations need a legal reason to use your personal information. If they don’t have one, they can’t use it. There are several legal grounds that enable data processing. Below are the most relevant grounds you should be aware of.
With your consent
There are some activities where we process personal information with your consent. For example, where we want to send you marketing messages by email, we would ask your permission first and you could opt-out at any time. However, if you opt-out or withdraw consent, we may not be able to provide the product or service you have requested.
To enter into and fulfill a contract
We also process your personal information in order to fulfill a contract we have with you. For example, we would use your information to provide you with access to your digital subscription or other products you have signed up for or to provide a prize to which you are entitled.
For a legitimate interest
We may use your information where there is a legitimate reason to do so. For example, we may use your information where it would help achieve our business objectives or to facilitate a benefit to you or someone else.
We only rely on legitimate interests if the reason for using your information is fair and lawful. Where we want to rely on legitimate interests as a legal basis, we will carry out a balancing test between our legitimate interests and your privacy rights.
Our legitimate interests in processing personal data include:
- to support individual and societal rights to receive information;
- to develop, deliver and maintain relevant and engaging products services and advertising;
- understanding when our audiences engage with us or other organizations;
- to build a clearer understanding of who our audiences are in order to better serve them;
- to carry on the business of a commercial organization; and
- to demonstrate that we provide services and products to agreed industry standards.
To comply with legal obligations
There may be situations where we need to use your information to comply with legal and regulatory obligations or defend claims. This may include publishing information about prize winners, for example.
In the table below, we have listed the main reasons we process your information and the legal bases that are available to us. The specific legal basis we use will depend on the activity the information is used for. Please keep in mind that while we will rely on one legal basis, if that is no longer available to us, we may be able to rely on another.
| Purposes of processing (why we use your information) | Lawful basis for the use of your information – this may depend on the specific activity |
|---|---|
| To provide products and services, improve your experience and manage our relationship with you | Consent, Fulfill a Contract, Legitimate Interest, Legal Obligation |
| To personalize content and offers | Consent, Fulfill a Contract, Legitimate Interest |
| To send you direct marketing | Consent, Legitimate Interest |
| To send you product-related and similar product and services communications | Fulfill a Contract, Legitimate Interest |
| To conduct market research and perform analytics | Consent, Legitimate Interest |
| To gain audience insights | Consent, Legitimate Interest |
| To disclose your information as permitted or required by law | Consent, Performance of a Contract, Legal Obligation |
| To ensure our services are used appropriately | Legitimate Interest, Legal Obligation |
| As part of the sale of our business | Consent, Legitimate Interest, Legal Obligation |
| To take payments, check your identity and conduct credit checks | Consent, Performance of a Contract, Legitimate Interest, Legal Obligation |
| For analysis, audience insights, business efficiencies, content personalization and to deliver relevant advertising | Legitimate Interest |
| For analytics and analysis about customer interaction with products and services, content personalization, and to deliver relevant advertising | Legitimate Interest |
| To ensure that our products and services conform to agreed industry standard standards | Legitimate Interest |
How We Use Personal Information
To provide products and services and improve experience
We will use your information to provide you with products and services you have asked for and to manage our relationship with you, including allowing you to interact, comment, and participate in online games, contests and reward programs.
We may use your information to monitor, improve and protect our products, content, services and websites, both online and offline. We may also provide you with help and support where we believe it is required. For example, if you have provided your contact information, we may contact you when a checkout journey is not completed.
To personalize content and offers
We sometimes make assumptions about your interests based on the way you interact with our products and services and the information we hold about you.
Knowing these preferences also allows us to understand the products, content and services our customers like, letting us focus our efforts on developing those areas. We may also use this information to make decisions about what direct marketing to show you.
“Do Not Track” browser settings
If you choose to turn on Do Not Track setting in your browser, your browser sends a special signal to websites, analytics companies, ad networks, plug-in providers, and other web services you encounter while browsing to request that they stop tracking your activity. Currently our websites and apps are not designed to respond to “Do Not Track” signals.
To send you direct marketing
Where we have your permission or a legitimate interest, we may send you direct marketing. This may include communications by post, telephone, email, messages (to your mobile devices, through social media (such as Facebook, Instagram and Twitter) and on our website, or on other websites, as you browse the internet. The communications may contain information about our products, services, events and offers. We may also send you information, offers and promotions from our commercial customers and partners where you have given your consent.
You will be able to opt-out of direct marketing by following the instructions in the communication.
To send you information about similar products and services
We will send you information, exclusive offers and promotions about similar products and services to those that you have already engaged with or purchased, where you have indicated that you are happy to receive them.
You will always be able to opt-out of these, either in the communications themselves.
To send you product-related communications
As part of the products and services you have with us, you are entitled to receive newsletters, bulletins, and other “in-life” communications that relate to those products and services, including triggered emails, such as updates you make.
You will be told about the types of communications you will receive when you sign up and you will be able to unsubscribe at any time. However, if you do, you may not get the most out of the products and services you have signed up to.
Service messages
We may send you service messages by email, SMS, social media, post, or other channels, containing important information about changes to our service or your account. These communications are a fundamental part of our products and services.
To conduct market research and perform analytics
We may use your information to conduct market research to improve the services we offer and to develop new products and services. You will be able to opt-out of receiving market research surveys by following the instructions in the communication.
To disclose your information as permitted by law
Your information may be disclosed where we are permitted by law to do so, for example where we get police requests or regulatory inquiries. We may also disclose your personal information where we are allowed by law to protect or enforce our rights or the rights of others and for the detection and prevention of crimes, such as fraud.
To ensure our services are used appropriately
If you post or send offensive or objectionable content, or otherwise engage in disruptive behavior anywhere on or to any of our websites or apps, we may use your information to stop such behavior. This may involve informing and responding to relevant third parties such as law enforcement agencies about the content and your behavior.
As part of the sale of our business
If we sell part or all of our business, customer information may be one of the transferred business assets. If this happens, your information may be disclosed to our advisers and any prospective purchaser’s advisers and will be passed to the new owners of the business for the purposes set out in this Policy and to ensure continuity of your selected services.
To ensure that our products and services conform to agreed industry standards
We may share your information with auditors for the purposes of verifying that we comply with relevant standards. For example, we may ask third party auditors to assess our compliance with information security and Privacy by Design best practice. This may require them to access your information in our systems.
Linked services
Our services may be linked to websites and apps operated by third party companies, and may carry advertisements or offer content developed and maintained by unaffiliated companies. We are not responsible for the privacy practices of these companies, and once you leave the Alpha Social Media Inc site you should check the applicable privacy policy of the other service.
How We Share Your Information
Sharing between business associations
Your information could be shared between business associations for use in accordance with this Policy. For example, we may share your information, with your consent, to assist you in enrolling in a business training program with another business association.
Access & Control of Your Information
Updating your information
Please ensure you update your personal information or tell us if it changes or is inaccurate. You can update your details, for example, your email address, in your account settings or an equivalent section if you are a subscriber. You may also email our Customer Services team at info@calmillar.com.
Controlling direct marketing
You can change your mind about receiving direct marketing or other communications you receive from us, such as bulletins and other information about your chosen products and services by contacting us using the details below, or by following the unsubscribe instructions in the relevant communication.
Withdrawing consent for processing
Where we may rely on your consent to process personal information, you have the right to withdraw that consent at any time. Often, this can be managed contacting us – such as your consent for us to send you communications. Otherwise, please contact us at info@alphasocialmediainc.com with details of your request. In some instances, we may still have an alternative legal basis to continue to process that personal information and we will inform you of that. If you do withdraw consent, we may not be able to provide the product or service you have requested.
Other rights
You may request a copy of your personal information from Calmillar.com which may hold personal information about you, as well as the right to not be profiled. You can also ask us to correct any inaccuracies in your personal information.
In some circumstances, you may be able to ask us to transfer the information you have provided to us to another organization. Similarly, you may be able to transfer your information from another organization to us, but you should check with us first if this is possible.
You may also have the right to object, erase, or restrict our processing of your information – for example, where we process personal data because this is in our legitimate interests, you may object to this. We will need to carefully consider your request, as there may be circumstances which require us, or allow us, to continue processing your data.
To exercise any of these rights, please contact us at info@calmillar.com. These rights may be restricted by law, for example, we may not be able to provide a copy of your data where the data we hold is also the data of a third party and it is not reasonable to disclose this information.
Complaining to the Regulator
If you have a comment, concern or suggestion, please contact us at info@alphasocialmediainc.com. If you have a complaint and we cannot resolve the matter, you have the right to complain to the Office of the Information Commissioner of Canada http://www.oic-ci.gc.ca/eng/. Alternatively, you may contact the data protection regulator responsible for your country or region.
Retention of Personal Information
We will retain your information for as long as necessary for the uses set out in this Policy, or while there is a legitimate reason for doing so. If you ask us to delete your information before that time, we may not be able to do so due to technical, legal, regulatory or contractual constraints. For example, if Calmillar.com provides any paid for services to you, we are required under Canadian tax law to keep your basic personal data (name, address, contact details) for a minimum of 7 years after which time it will be destroyed.
If you ask for your account to be closed, we will do this as soon as is reasonably possible subject to any applicable terms and conditions relating to the account. Personal information from closed accounts is retained in order to comply with legal obligations, prevent fraud, collect any fees owed and to resolve disputes.
Cookies and Similar Technologies
Introduction
This section covers our use of cookies and similar technologies.
What are Cookies?
Cookies and other online tracking technologies are small bits of data or code that are used to identify your devices when you use and interact with our websites and other services. They are often used for remembering your preferences, to identify popular news stories, to remember you’re logged in and allowing you to comment on stories.
Our legal bases for cookies and similar technologies
Placing cookies: in order to place cookies, tags and other technologies on your browser or device, we need to have your permission. We do this by providing a clear notice in the form of a cookie banner that tells you what cookies are used for, as well as providing you with useful information about the technologies we use and a link to this Policy. You’ll need to indicate your acceptance of our use of cookies. On a mobile device this might be by swiping a banner, pressing a button, or using facial recognition.
You are able to opt-out of the use of cookies. For more information, see the section on Managing Cookies.
Using information collected from cookies: where we want to use the information that cookies and similar technologies collect, we either need your consent or a legitimate interest. In practice it will not always be practical to get opt-in consent as doing so with cookie banners and pop-ups would disrupt your use and enjoyment of our sites and content. This is why we usually rely on our legitimate interests to use the data collected by cookies. To do this we conduct an assessment to make sure the purposes for which we use your data are fair and that your privacy rights are considered. We only rely on legitimate interests where your rights do not override our interests in using the data.
What Cookies Do We Use and Why?
Essential cookies and similar technologies
These are vital for the running of our services on our websites and apps. Without the use of these cookies, parts of our websites would not function. For example, Times+ uses cookies to help us identify which of our readers have a subscription in order to access content they are entitled to on the website. We use these cookies to tell if you’re logged in to your account, which allows extra functionality, such as commenting on stories.
Analytics cookies and similar technologies
These collect information about your use of our websites will enable us to improve the way it works. For example, analytics cookies show us which are the most frequently visited pages on the Calmillar.com website, allowing us to provide more engaging posts.
They help us record how you interact with our websites, such as how you navigate around pages and from page to page, identifying improvements we can make to the visitor’s journey. They also help identify any difficulties you have accessing our services, so we can fix any problems. Additionally, these cookies allow us to see overall patterns of usage at an aggregated level.
Functional/preference cookies and similar technologies
These cookies collect information about your choices and preferences and allow us to remember things like language, your username (so you can log in faster), text size, and location, so we can show you relevant content to where you are. They allow us to customize the services you have accessed.
Web beacons and tracking pixels
These are bits of data that count the number of users who access a website or webpage and can also allow us to see if a cookie has been activated. Web beacons used on web pages or in emails allow us to see how successful an article has been, or whether an email message was successfully delivered and read in a marketing campaign.
Web beacons are also used to verify any clicks through to links in emails. We may use this information to help us identify which emails are more interesting to.
Tracking URLs
Tracking URLs are a special web link that allows us to measure when a link is clicked on. They are used to help us measure the effectiveness of campaigns and advertising and the popularity of articles that are read.
Device fingerprinting
We may collect and analyze a device’s browser information to help identify that device, present content correctly, conduct analytics and help prevent and detect fraud.
If you access our services from a mobile device
We may collect a unique device identifier assigned to that device, geolocation data, and other transactional information for that device. We may also use the unique identifier to validate free trials, for example.
How We Use Cookies and Similar Technologies
As well as the uses already identified above, we use cookies and similar technologies to:
Protect our networks
Cookies and similar technologies help us identify and prevent threats to our sites. They are necessary to protect your information and our business from outside threats.
Allow you to access our services
Cookies and similar technologies permit your connection to our websites: our servers receive and record information about your computer, device, and browser, including potentially your IP address, browser type, other software or hardware information, and your geographic location.
Assess usage of services
We use information about your usage of our services, websites and apps, such as pages you have visited, content you have viewed, search queries you have run, and advertisements you have seen or interacted with to assess how our services are used.
Provide eCommerce functionality
Cookies and similar technologies help us provide functionality that you need to navigate our sites, select products and services and purchase them.
Provide relevant content
The content on our websites and in our communications with you may be adjusted depending on what we know about the content, products and services that you like. This means we can highlight content and articles that we believe will be of interest to you. We provide personalisation by using cookies, IP addresses, web beacons, URL tracking and mobile app settings.
Managing Cookies
Below you will find useful information about how to manage the use of cookies on our sites. If you have any questions, please contact info@alphasocialmediainc.com.
Controlling OBA cookies
In addition to being able to control cookies by changing the settings in your browser on your computer, or in your mobile device’s settings, you can also control which companies can set cookies and similar technologies on your devices, by visiting the following links (you’ll need to turn any cookie or ad blockers off for the control pages to show which companies you can opt-out of):
- Internet Advertising Bureau (IAB) Your Online Choices website provides more information about controlling cookies. It also provides an easy way to opt-out of behavioral advertising from each (or all) of the networks represented by the European Interactive Digital Advertising Alliance http://www.youronlinechoices.com/uk/your-ad-choices.
- The Network Advertising Initiative (NAI) control page allows you to control behavioral advertising from each of the ad networks represented by the NAI.
- The Digital Advertising Alliance’s self-regulatory program for online behavioral advertising control page allows you to control behavioral advertising from the ad networks it represents.
- The News Connect website provides more information, and an easy way to opt-out.
Importantly, these ad networks set cookies to remember that you have chosen to opt-out. If you clear your cache the opt-outs will not be applied, and you would need to opt-out again.
Controlling web beacons
You can prevent web beacons from tracking your activity, although you won’t be able to decline receiving them in emails. For information about managing your cookie options, please visit http://www.allaboutcookies.org/.
Please note that by blocking any or all cookies, you may not have access to certain features, content, or personalization available on our websites or apps.
Changes to This Policy
From time to time, we make changes to our Privacy Policy. This may be in relation to changes in the law, best practice, changes in our services or treatment of your personal information. Where necessary, we will seek your consent to these changes. We will always display clearly when the privacy policy was last amended on the website.
Contact Us
In addition to any general data protection enquiries you may have, you can contact our Data Protection Officer at info@calmillar.com.
