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Privacy Policy

Astroff Consultants Inc. - Privacy Policy

Please read this Privacy Policy carefully before using this Site.

Last updated on: January 8, 2019

Astroff Consultants Inc. (“us”, “we,” or “our”) recognizes the importance of the privacy of our users.  We have developed this Privacy Policy (“Privacy Policy”) that covers how we collect, process, use, disclose, and protect your personally identifiable information (“PII”), such as the PII we may collect when you use our website astroffconsultants.com  and all sites linked thereto which are controlled or hosted by us, as well as your access to or use of our sites by means of a computer, a mobile device or a mobile application and any mobile application operated by us that does not access our sites (“Site” or “Sites”), when you register to use our products or services (“Services”), and when you contact us by email, text, chat, or phone.  By using the Sites or providing your PII to us, you consent to the terms of this Policy.

This Privacy Policy is incorporated into the Terms and Conditions of Use by reference, and forms part of the Terms and Conditions of Use.

Astroff has the right, in its sole discretion, to add to, remove, modify or otherwise change any part of this Privacy Policy, in whole or in part, at any time. You should review this Privacy Policy periodically as we may modify it from time to time, and such changes will be effective upon our posting them to our Sites. If we make any material changes to this Privacy Policy, we will update the “Last updated on” date above.  We encourage you to check our Privacy Policy whenever you use our Sites to see if it has been updated since your last visit. Where consistent with applicable law, your continued use of our Sites and/or the Services after we have changed the Privacy Policy signifies your acceptance of the revised terms. Under certain circumstances (e.g., with respect to certain material changes to this Privacy Policy), we may also elect to notify you through additional means, such as posting a notice on the front page of the Sites or by means of an e-mail that gives you the opportunity to indicate whether you consent to the proposed changes.

We ask that you read this Privacy Policy carefully. If you have any questions, feel free to contact our privacy officer by email or by mail and by using the contact information provided under Section 8 below.

 1.  Your Personal and Non-Personal Information

There are two basic types of data that we collect on our Sites: PII and non-personal information.

PII is data that that can be used to identify or contact a single person or entity, such as your email address or data about activities that are directly linked to you.

Non-personal information is data we collect in a form that does not, on its own, permit direct association with any specific individual, which may include demographic data. Data on how you use our Sites may be collected and combined with data about how others use our Sites, but no PII will be included in the resulting data set. This type of data helps us understand trends in our users’ needs.  We may collect, use, transfer, and disclose non-personal information for any purpose, such as to better understand and improve our Sites, and for advertising and marketing purposes.

We may receive certain types of data automatically whenever you interact with us. For example, when you use our Sites our systems may automatically collect your IP address and the type of browser or operating system you use.

We may also collect standard access data, such as the time, date and usage of Site access. We use such data to help us understand how our visitors use our Sites including visitor count and aggregated statistics about Site usage.

We commonly collect, use, and process basic contact data, biographical data, and payment data.  You may provide us your PII when you email us, contact us via our Sites or social media accounts, communicate with us via telephone or text messaging, register for our Services, or open a support ticket.

When you register with us, we may collect a variety of PII, including your name, date of birth, mailing address, phone number, email address, contact preferences, and credit card and other payment information.  We also collect any other information you provide to us, such as academic and employment information.  We use this information to communicate with you, including by email and/or SMS or text messages, about our Services and to respond to your questions, to offer you advice through our Services, or to provide you with additional content or information that might be relevant or interesting to you.

Users can create content on our Sites or Services, such as by uploading files or providing responses to questions using the assets we provide. If you decide to share this information with third parties, we cannot prevent such information from being used in a manner that might violate this Privacy Policy, the law or your personal privacy.  We assume no responsibility or liability of any nature whatsoever arising out of or in relation to any information shared by you with third parties.  Review carefully the terms and conditions governing your use of any website where you intend to share your information as you will be bound by, and your rights, duties, and remedies will be governed by, those terms and conditions.

Users can also post materials and other information through their use of our community forums.  You will determine what materials and information you post, and because those postings will be viewable by other users and by the public, you should have no expectation of privacy with respect to such postings. By posting or submitting your content to our Sites and/or Services, you represent and warrant that you own or otherwise control all of the rights thereto, and that use of your content on the Sites and/or Services will not infringe or violate the rights of any third party or any applicable law.

We have many email newsletters and marketing preferences for you to choose from and realize your preferences may change over time. To change your e-mail newsletter preferences, or to unsubscribe, please click on the relevant link in our emails and follow the directions.

Cookies and Other Technologies

Our Sites use cookies. When you visit our Sites, our servers send a cookie to your computer. Cookies allow our server computer to recognize your computer to make interactions with our Sites simple and meaningful. If you do not wish to receive cookies, most browsers allow you to be alerted when a cookie is sent to your computer, so you can decide whether to accept it.  Please note that if you decide not to accept our cookies, you may not be able to use certain features of our Sites.

We use cookies that collect data about how people use our Sites, including which pages visitors go to most often, how fast they load, and other statistical data. All data these cookies collect is aggregated and provide information on how our Sites are used so that we can optimize our visitors’ experience.

We use third-party service providers to evaluate the use of our Sites and our Services. We or our service providers use automated devices and applications to evaluate use of our Sites and Services. We or our service providers use these tools to help us improve our Sites, Services, performance, and user experiences. We or these entities may use cookies and other tracking technologies, such as web beacons or Flash cookies, to perform their services.

Special rules for children

Although most portions of our Sites are directed to general audiences, we do not knowingly collect PII from children under 18. If we learn we have collected or received Personal Information from a child under 18 without verification of parental consent, we will endeavor to delete that information. If your child wants to register on or participate on our Sites, we will only do so if we have your consent. During the registration process, we may collect certain information from your child, including PII such as their name or e-mail address, as well as a parent or guardian’s email address in order to obtain your consent. We will then send you an e-mail (which will include a link to this Privacy Policy), advising you that your child has expressed interest in our Sites, and request that you reply by e-mail if you consent to your child’s participation. In the reply e-mail, we may request further PII from you (as defined in the main part of this Privacy Policy) about you and/or your child, but we will not request such information from your child. We will then send you a confirmatory e-mail of your child’s registration. You have the right to review your child’s PII that we collect or use, to have that information deleted, and/or to refuse to permit its further collection or use. Parents can contact our Privacy Officer and we will respond to their requests. We may use the PII to provide the child with access to and use of our Sites and Services. We do not condition a child's participation in any of our online activities on the disclosure of more information than is reasonably necessary to participate in the activity. PII collected on or through any portions of our Sites (as outlined above) may be shared by us with service providers with whom we contract to operate our Sites and some of our Services. These service providers will use such PII of visitors to our Sites only for the purposes of carrying out these operations. To the extent required or permitted by law, we may also collect, use and disclose such PII in connection with security-related or law enforcement investigations or in the course of cooperating with authorities or complying with legal requirements. We may also use Sites users’ information as permitted by law to protect our rights or property, our Sites, or their users and their safety. As set forth above, we endeavor to maintain the confidentiality, security, and integrity of the PII collected from your child. Other than with our service providers and as described above, we will not share your child’s PII with third parties.

2.  USE OF PII

All PII and content submitted by you is stored in our database and may be archived elsewhere. Our system administrators and support personnel will have access to PII that we process. In general, we use PII internally to serve our users and enable them to take maximum advantage of our Services. For example, PII is used to resolve technical support cases, to conduct marketing analysis, to create an individual profile and provide personalized services, to provide services or complete transactions you have requested, to anticipate and resolve problems with our Services, and to create and inform you of new products and services that better meet your needs. We may communicate with you at any of the points of contact that you provide to us for any of the aforementioned purposes.

We do not rent, sell, or share PII about you with other people or non-affiliated companies except (i) as necessary to complete a transaction you have requested, (ii) as necessary to perform internal analyses, technical support, and other business functions, (iii) as part of a business transfer, or (iv) when required by law or permitted in order to protect our rights, property, or safety.

In accordance with our Terms and Conditions, Recordings may be used by us for our internal purposes, for development of new products and services, and for any purpose expressly permitted hereunder. Any PII of yours that may be incorporated into or forms part of any Recordings will not be incorporated into any products or services offered or made available by us.
Unless you choose to do so, we will not disclose your PII to third parties for their direct marketing purposes. With your consent, we may disclose your PII to third parties so that they may provide you with products and services that you have requested.

Vendors or service providers we may disclose PII to include:

  • Independent contractors who supply the Services
  • Cloud-based hosting providers
  • Cloud-based CRM solutions
  • Videoconferencing tools
  • Marketing automation and data enrichment platforms
  • Customer relationship management platforms
  • Customer support and community platforms
  • Social media platforms
  • Human resource information service platforms
  • Accounting and finance platforms
  • User analytics platforms
  • Consulting firms

We may also disclose the information that we collect about you in the following ways:

  • We may disclose your information to another entity as part of a merger or acquisition, creation of a separate business to provide the Services or fulfill products, sale or pledge of company assets, as well as in the event of an insolvency, bankruptcy, or receivership.
  • We may disclose your information to comply with the law, or a judicial proceeding, subpoena, court order or other legal process. We may disclose your information when we believe it is necessary to comply with a legal process or authority to investigate, enforce or apply our policies; to initiate, render, bill, and collect amounts owed to us; to protect our rights and/or property. We may also release PII when we believe it is necessary to prevent or act regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms and Conditions of Use or this Privacy Policy, or as evidence in litigation in which we are involved.
  • We may disclose aggregate or de-identified information about our users for marketing, advertising, research or similar purposes.

We retain personal data only for as long as necessary for a specified purpose or legal requirement wherever technically and operationally feasible and in accordance with any applicable regulations.

3.  THIRD-PARTY SITES

Co-branded websites and links to third party websites may be accessible through our Sites. Third parties may have their own privacy policies and data collection practices that differ from ours and we are not responsible for the content or the data collection practices of those sites. We are not responsible and assume no liability for the information practices of such third-party websites, and we encourage you to review and understand their privacy practices before deciding to provide them with data.

4.  NETWORK AND DATA SECURITY

We have taken steps to help protect the information we collect from loss, misuse, unauthorized access, disclosure, alteration, and destruction. However, no data security measures can guarantee 100% security.  Users should take steps to protect against unauthorized access to their accounts by, among other things, choosing a robust password that nobody else knows or can easily guess and keeping their log-in and password private.  We are not responsible for any lost, stolen, or compromised passwords or for any activity on an account because of unauthorized password activity.

In compliance with applicable law, we will notify governmental authorities of any data security breach of which we become aware as and when required to do so in accordance with applicable laws, and, if it involves a high risk to your personal information, we will notify you as well.

5.  ACCESS AND CONTROL OF PII

You can access, change, or update PII you have provided and your preferences regarding information you receive from us by emailing us. You may also contact us using the information found in the Contact Us section of this Privacy Policy to exercise your rights described in this Section. We will implement any requested changes as soon as we reasonably can, subject to reasonable limitations.

Please note that data that you may wish to remove may remain in our databases or backups because it is not always possible to completely remove or delete data from those locations.

6.  INTERNATIONAL TRANSFER OF PII

In this Section 6, we provide information about the circumstances in which the PII of users who are resident in or subject to the European Commission’s (“EC”) General Data Protection Regulations (“GDPR”) (“EU users”) may be transferred to countries outside the European Economic Area (“EEA”).

We have offices and facilities in Canada. The EC has made an "adequacy decision" with respect to the data protection laws of Canada. Transfers to Canada will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained on the internet.

The hosting facilities for our Sites are situated in Canada and the United States. The EC has made an "adequacy decision" with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the EC a copy of which you can obtain on the internet.

Our service providers are situated in Canada and the United States. The EC has made an "adequacy decision" with respect to the data protection laws of each of these countries. Transfers to Canada and the United States will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the EC, a copy of which can be obtained on the internet.

You acknowledge that PII that you submit for publication through our Sites or Services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

7.  OTHER SPECIFIC USER TERMS

(i)         EU users

In this section we have summarized the rights that EU users have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

Your principal rights under data protection law are:

(a)      the right to access;

(b)      the right to rectification;

(c)      the right to erasure;

(d)      the right to restrict processing;

(e)      the right to object to processing;

(f)       the right to data portability;

(g)      the right to complain to a supervisory authority; and

(h)      the right to withdraw consent.

You have the right to confirmation as to whether or not we process your PII and, where we do, access to the PII, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your PII. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can access your PII by contacting us.

You have the right to have any inaccurate PII about you rectified and, taking into account the purposes of the processing, to have any incomplete PII about you completed.

In some circumstances you have the right to the erasure of your PII without undue delay. Those circumstances include: the PII is no longer necessary in relation to the purposes for which it was collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the PII has been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

In some circumstances you have the right to restrict the processing of your PII. Those circumstances are: you contest the accuracy of the PII; processing is unlawful but you oppose erasure; we no longer need the PII for the purposes of our processing, but you require the PII for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your PII. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

You have the right to object to our processing of your PII on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the PII unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

You have the right to object to our processing of your PII for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your PII for this purpose.

You have the right to object to our processing of your PII for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

To the extent that the legal basis for our processing of your PII is:

(a)      consent; or

(b)      that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,

and such processing is carried out by automated means, you have the right to receive your PII from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

If you consider that our processing of your PII infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

To the extent that the legal basis for our processing of your PII is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

With regard to the PII processed within the scope of this Privacy Policy, Astroff Consultants Inc. is the data controller.

You may exercise any of your rights in relation to your PII by written notice to us, in addition to the other methods specified in this Section 7.

(ii)        California users

We do not track our customers over time and across third party websites to provide targeted advertising and therefore do not respond to Do Not Track (“DNT”) signals. However, some third party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you and may provide for you to initiate a DNT signal.  Third parties that may place content embedded on our websites such as a social or community feature may set cookies on a user’s browser and/or obtain information about the fact that a web browser visited one of our Sites from a certain IP address. Third parties cannot collect any other personally identifiable information from our websites unless you provide it to them directly.

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits users who are California residents to request and obtain from us once a year, free of charge, information about their PII that we disclosed to third parties for direct marketing purposes in the preceding calendar year. If you are a California resident and would like a copy of this notice, please send an e-mail to privacy@astroffconsultants.com or write to us at 4711 Yonge Street, 10th Floor, Toronto, Ontario, Canada M2N 6K8. Not all information sharing is covered by the "Shine The Light" requirements and only information on covered sharing will be included in our response. Under California law, businesses are only required to respond to a request once during any calendar year.

8.  CONTACT US

If you have any questions or complaints about how we process your PII, please contact us via our contact form or using the information below.

Astroff Consultants Inc.
4711 Yonge Street, 10th Floor
Toronto, Ontario Canada M2N 6K8
Email: privacy@astroffconsultants.com