Privacy Policy

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You. We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretations and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

• Account means a unique account created for You to access Our Service or parts of Our Service.
• Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
• Application refers to Pragmatica, the software program provided by the Company.
• Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Pragmatica LLC, 269 Harrowsmith Drive, Mississauga, ON, L5R1R3.
• Country refers to: Ontario, Canada
• Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
• Personal Data is any information that relates to an identified or identifiable individual.
• Service refers to the Application and the services provided by Company using Application.
• Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
• You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name
• Phone number
• Address, State, Province, ZIP/Postal code, City
• Contact preferences
• Usage Data

Usage Data

Usage Data is collected automatically when using the Service. Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), the sections of Our Service that You visit, the time and date of Your visit, the time spent, unique device identifiers and other diagnostic data.

Use of Your Personal Data

The company may use Personal Data for the following purposes:

• To provide and maintain Our Service, including to monitor the usage of Our Service.
• To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
• For the performance of a contract: the development, compliance, and undertaking of the purchase contract for the products, items, or services You have purchased or of any other contract with Us through the Service.
• To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products, or contracted services, including the security updates, when necessary or reasonable for their implementation.
• To provide You with news, special offers, and general information about other goods, services, and events which We offer that are similar to those that You have already purchased or enquired about unless You have opted not to receive such information.
• To manage Your requests: To attend and manage Your requests to Us.
• For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about Our Service users is among the assets transferred.
• For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of Our promotional campaigns, and to evaluate and improve Our Service, products, services, marketing, and Your experience.

We may share Your personal information in the following situations:

• With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of Our Service.
• For business transfers: We may share or transfer Your personal 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.
• With Affiliates: We may share Your information with Our affiliates, in which case We will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners, or other companies that We control or that are under control with Us.
• With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
• With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
• With Your consent: We may disclose Your personal information for any other purpose with Your consent.

Legal Bases We Rely on to Process Your Information

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.

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 manner.
• 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 a 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.

If You are located in the EU or UK, this section applies to you

The General Data Protection Regulation (GDPR) and UK GDPR require Us to explain the valid legal bases We rely on in order to process Your personal information. As such, We may rely on the following legal bases to process Your personal information:

• Consent: We may process Your information if You have given Us permission (i.e., consent) to use Your Personal Information for a specific purpose. You can withdraw Your consent at any time.
• Performance of Contract: We may process Your personal information when We believe it is necessary to fulfill Our contractual obligations to you, including providing Our Services or at Your request prior to entering into a contract with you.
• Legitimate Interests: We may process Your information when We believe it is reasonably necessary to achieve Our legitimate business interests and those interests do not outweigh Your interests and fundamental rights and freedoms. For example, We may process Your personal information for some of the purposes described in order to:
  • Analyze how Our Services are used so We can improve them to engage and retain users.
  • Support Our marketing activities
  • Diagnose problems and/or prevent fraudulent activities.
  • Understand how Our users use Our products and services so We can improve user experience.

  If You are located in the EU or UK, this section applies to you

  The General Data Protection Regulation (GDPR) and UK GDPR require Us to explain the valid legal bases We rely on in order to process Your personal information. As such, We may rely on the following legal bases to process Your personal information:

  • Consent: We may process Your information if You have given Us permission (i.e., consent) to use Your Personal Information for a specific purpose. You can withdraw Your consent at any time.
  • Performance of Contract: We may process Your personal information when We believe it is necessary to fulfill Our contractual obligations to you, including providing Our Services or at Your request prior to entering into a contract with you.
  • Legitimate Interests: We may process Your information when We believe it is reasonably necessary to achieve Our legitimate business interests and those interests do not outweigh Your interests and fundamental rights and freedoms. For example, We may process Your personal information for some of the purposes described in order to:
    • Analyze how Our Services are used so We can improve them to engage and retain users.
    • Support Our marketing activities
    • Diagnose problems and/or prevent fraudulent activities.
    • Understand how Our users use Our products and services so We can improve user experience.
  • Legal Obligations: We may process Your information where We believe it is necessary for compliance with Our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend Our legal rights, or disclose Your information as evidence in litigation in which We are involved.
  • Vital Interests: We may process Your information where We believe it is necessary to protect Your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.
• Legal Obligations: We may process Your information where We believe it is necessary for compliance with Our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend Our legal rights, or disclose Your information as evidence in litigation in which We are involved.
• Vital Interests: We may process Your information where We believe it is necessary to protect Your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

Retention of Your Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with Our legal obligations (for example, if We are required to retain Your data to comply with applicable laws), resolve disputes, and enforce Our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Transfer of Your Data

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ from those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Deleting Your Data

You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You.

Our Service may give You the ability to delete certain information about You from within the Service.

You may update, amend, or delete Your information at any time by signing in to Your Account, if You have one, and visiting the account settings section that allows You to manage Your personal information. You may also contact Us to request access to, correct, or delete any personal information that You have provided to Us.

Please note, however, that We may need to retain certain information when We have a legal obligation or lawful basis to do so.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition, or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation.
• Protect and defend the rights or property of the Company.
• Prevent or investigate possible wrongdoing in connection with the Service.
• Protect the personal safety of Users of the Service or the public.
• Protect against legal liability.

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

California Residents

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 the 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

This section applies only to California residents. Under the California Consumer Privacy Act (CCPA), You have the rights listed below.

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 of 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.

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 or share personal information to third parties;
  • the categories of personal information that We sold, shared, or disclosed for a business purpose;
  • the categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose;
  • the business or commercial purpose for collecting, selling, or sharing personal information; and
  • the specific pieces of personal information We collected about you.

CCPA Privacy Notice

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.

Right to Limit Use and Disclosure of Sensitive Personal Information

We do not process consumer's sensitive personal information.

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. This may include asking You to provide information to match with what we have on file and using various verification methods.

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.
• You may request to opt out from future selling or sharing of Your personal information to third parties.

To exercise these rights, You can contact Us by visiting pragmatica.ca, by emailing info@pragmatica.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.

Colorado Residents

This section applies only to Colorado residents. Under the Colorado Privacy Act (CPA), You have the rights listed below. However, these rights are not absolute, and in certain cases We may decline Your request as permitted by law.

• Right to be informed whether or not We are processing Your personal data
• Right to access Your personal data
• Right to correct inaccuracies in Your personal data
• Right to request deletion of Your personal data
• Right to obtain a copy of the personal data You previously shared with us
• Right to opt out of the processing of Your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")

To submit a request to exercise these rights described above, please email info@pragmatica.ca or visit pragmatica.ca.

If We decline to take action regarding Your request and You wish to appeal Our decision, please email Us at info@pragmatica.ca. Within forty-five (45) days of receipt of an appeal, We will inform You in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.

Connecticut Residents

This section applies only to Connecticut residents. Under the Connecticut Data Privacy Act (CTDPA), You have the rights listed below. However, these rights are not absolute, and in certain cases We may decline Your request as permitted by law.

• Right to be informed whether or not We are processing Your personal data
• Right to access Your personal data
• Right to correct inaccuracies in Your personal data
• Right to request deletion of Your personal data
• Right to obtain a copy of the personal data You previously shared with us
• Right to opt out of the processing of Your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")

To submit a request to exercise these rights described above, please email info@pragmatica.ca or visit pragmatica.ca.

If We decline to take action regarding Your request and You wish to appeal Our decision, please email Us at info@pragmatica.ca. Within sixty (60) days of receipt of an appeal, We will inform You in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.

Virginia Residents

Under the Virginia Consumer Data Protection Act (VCDPA):

• Consumer means a natural person who is a resident of the Commonwealth acting only in an individual or household context. It does not include a natural person acting in a commercial or employment context.
• Personal data means any information that is linked or reasonably linkable to an identified or identifiable natural person. "Personal data" does not include de-identified data or publicly available information.
• Sale of personal data means the exchange of personal data for monetary consideration.

If this definition "consumer" applies to you, We must adhere to certain rights and obligations regarding Your personal data.

Your rights with respect to Your personal data

• Right to be informed whether or not We are processing Your personal data
• Right to access Your personal data
• Right to correct inaccuracies in Your personal data
• Right to request deletion of Your personal data
• Right to obtain a copy of the personal data You previously shared with us
• Right to opt out of the processing of Your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")

Exercise Your rights provided under the Virginia VCDPA by contacting Us by email at info@pragmatica.ca or visit pragmatica.ca.

If You are using an authorized agent to exercise Your rights, We may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on Your behalf.

Verification process

We may request that You provide additional information reasonably necessary to verify You and Your consumer's request. Upon receiving Your request, We will respond without undue delay, within forty-five (45) days. The response period may be extended once by an additional forty-five (45) days when reasonably necessary.

Right to appeal

If We decline to take action on Your request, You can appeal Our decision by emailing info@pragmatica.ca. Within sixty (60) days of receipt of an appeal, We will inform You of any action taken in response, including reasons for the decisions. If Your appeal is denied, You may contact the Attorney General to submit a complaint.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Review, Update or Delete Your Data

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 visit: info@pragmatica.ca.

Contact Us

If You have any questions about this Privacy Policy, You can contact us by email at info@pragmatica.ca or visit pragmatica.ca.