Privacy Polivy for Jurismedia Inc., editor of the Margill financial software products
Table of contents
- Scope and application
- What is “Personal Information”?
- What categories of Personal Information do we collect?
- How do we collect your Personal Information?
- How do we use your Personal Information?
- When do we share your Personal Information with other organizations?
- What are your privacy choices?
- How do we protect your Personal Information?
- How long do we keep your Personal Information?
- Transborder transfers of Personal Information
- Access and correction of your Personal Information
- Changes to this Policy
- Information for individuals in the United Kingdom and the European Union
- Contact us
1. Scope and application
Jurismedia Inc., the company that operates Margill Finance Software (“Margill”, “we”, “us” or “our”), is committed to respecting the privacy and protecting the Personal Information of its customers.
2. What is “Personal Information”?
“Personal Information” means any information that directly or indirectly identifies, relates to, describes or can reasonably be associated with a specific individual. This includes information such as your name, contact information, and payment information. It may also include more technical information, such as your IP address, web browser settings, and unique device identifier, but only when that information identifies you as an individual. Information that is anonymized and cannot be associated with an identifiable individual is not considered Personal Information so long as it is reasonably foreseeable in the circumstances that it irreversibly no longer allows the person to be identified directly or indirectly.
3. What categories of Personal Information do we collect?
We limit the collection of Personal Information to what is reasonably necessary to provide our services to you.
Depending on your interaction with us, we may collect your personal and/or business contact information, payment information, your use of our products, and your activity on the web or other electronic networks. We may also need to collect certain information about individuals who interact with us in order to conduct fraud prevention checks. We collect Personal Information in a variety of ways, described below in the section How we collect your Personal Information.
- Contact information, such as last name, first name, company name, mailing address, telephone number and e-mail address.
- Payment information, such as credit or debit card number, PayPal account or bank check information when making purchases.
- Information about your use of our products, only to the extent necessary to provide you with technical support and to improve the performance and security of our software.
- Information about activity on the web or other electronic networks (i.e., technical information when you visit our Web site), including when you use our products and services. This information is collected through automated means, such as cookies, web beacons and similar technologies, and may include your IP address, unique device identifier, browser type, data about the web pages you have visited on our website, time and duration of a visit, information about your location, language preferences, etc. To learn more about how we collect and use this type of information, please see the section entitled How do we use your Personal Information? below.
4. How do we collect your Personal Information?
We may collect your Personal Information in a variety of ways, including directly from you, through our website and more generally from the following sources:
a. Directly from you
We may collect Personal Information directly from you, including in the following situations:
- when you fill out a form on our website to obtain a product, a price quote, a free trial or technical support;
- when we provide you with a product or service, including technical support and follow-up that may be associated with it;
- when you use our products or services, visit our website or contact us by phone, Skype or email.
b. Through our website, our products, and our services
- Web beacons: Web beacons are small files embedded in images on web pages. We may use these technical methods to analyze traffic patterns on our website. These technical methods may involve the transmission of information either directly to us or to another party authorized by us to collect information on our behalf. We may also use these technical methods in HTML emails we send to determine whether you have opened those emails or clicked on links in the emails. Information from the use of these technical methods may be collected in an anonymized form.
- Location Data: We may determine the approximate location of your computer or device based on your IP address. We collect and use this information to, for example, calculate the number of people visiting our site from certain geographic areas.
Customers using Margill finance software hosted by Margill in Cloud services may also enter Personal Information about their customers, business partners, etc. This Personal Information is processed only on the instructions of Jurismedia’s clients.
5. How do we use your Personal Information?
We may use your Personal Information for the following purposes, or otherwise with your consent, or as permitted or required by law
a. General business purposes
We may use your Personal Information for general business purposes such as providing or delivering a product or service you have requested, managing our ongoing business operations and website, preventing or mitigating business risks, and ensuring the security of information, systems or computer networks.
Specifically, we may use your Personal Information for the following purposes:
- Provide requested products and services, including our free trial offers;
- Process payments for our products and services;
- Offer assistance with payment problems;
- Follow up after a free trial to ensure your satisfaction;
- Provide technical support for our products and services;
- To improve the performance and functionality of our products and services;
- Follow up after purchase to ensure your satisfaction;
- Respect our legal, regulatory and professional obligations;
- To protect our business interests, collect debts and enforce our legal rights and interests;
- Create, administer and manage your account ; and
- Update your Personal Information.
b. Research and development purposes
We may use your Personal Information to understand and assess your interests and needs in order to improve our products and services and to develop new ones, as well as to assess potential improvements or other changes we may make to the functionality of our website. For example, we may use third-party analytics services, such as Google Analytics, to help us analyze how visitors use our website. Where required by law, we use anonymized information for these purposes.
6. When do we share your Personal Information with other organizations?
We may share your Personal Information with other organizations in the following situations, or otherwise with your consent as required by law:
Service Providers. We may share your Personal Information with our vendors or other organizations that provide services to us. Service providers that may receive Personal Information include payment services, web server hosting services, cloud storage services, and backup and archival service providers.
Other situations permitted or required by law. In certain circumstances permitted by law, we may share Personal Information without your consent, for example:
- in situations involving a threat to the safety of individuals (e.g., our customers or staff).
- to comply with a warrant or other order of a court or regulatory authority.
- to collect money owed.
- to investigate a violation of an agreement or applicable law.
- to provide information requested by an auditor.
- to detect, remove or prevent fraud.
- when necessary in connection with a proposed or completed business transaction, such as an asset or stock transfer or merger, in accordance with applicable legal requirements. For example, we may make your Personal Information available to advisors or (prospective) purchasers of our business if it is necessary to complete the transaction and continue the operation of the business.
7. What are your privacy choices?
By using our products and services and/or providing us with information in connection with the use of our products and services, you consent to the collection, use, and disclosure of your Personal Information in accordance with this Policy. In some cases, your consent may be “implied”, meaning that your agreement is assumed based on your action or inaction at the time of collection, use, or sharing of your Personal Information. We generally obtain your consent when we want to use Personal Information for a new purpose or for a purpose other than those identified in this Policy, in accordance with applicable privacy laws.
You have the following options regarding how we handle your Personal Information. If you are a resident of the European Union, you also have the rights set out in the section Information for individuals in the United Kingdom and the European Union.
a.Change your browser settings on your device
We use technology to enhance your experience as a user of our products and our Website and to present you with certain offers, including personalized advertisements. You can remove or disable some of these technologies at any time through your browser. However, if you do so, you may not be able to use some of the features of our website.
Please refer to your web browser’s instructions or help screen to learn how to block, delete and manage cookies on your computer or mobile device. You can also use the quick links below, depending on the type of browser you use: Google Chrome, Microsoft Edge, Firefox and Safari.
You can disable Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on for your browser.
b. Limiting the collection, use and disclosure of your Personal Information
You may withdraw your consent to the collection, use, and disclosure of your Personal Information in accordance with this Policy at any time upon reasonable written notice to the address listed below in the Contact Us section, subject to legal or contractual restrictions.
Withdrawing your consent may affect our ability to continue to provide you with the products and services you receive or would like to receive, as the ongoing use and disclosure of your Personal Information is necessary to make the product or service available to you. In some circumstances, legal requirements may prevent you from withdrawing your consent.
8. How do we protect your Personal Information?
We implement appropriate measures and controls to protect your Personal Information. These measures include restricting physical access to our offices and records, restricting access to your Personal Information to only those employees (including contract employees) who need it to perform their duties, restricting unauthorized access, disclosure, use, and mishandling of your Personal Information in our custody and control, storing archival materials with trusted third parties, off-site, in secure facilities, using firewalls, strong passwords, multi-factor authentication and file encryption for online activities.
Our goal is to prevent unauthorized access, loss, misuse, sharing, or modification of the Personal Information in our possession. We also use these safeguards when we delete or destroy your Personal Information.
a. Governance and privacy rules
We implement policies and practices to ensure the protection of your Personal Information. We have put a variety of measures to protect your Personal Information in place, appropriate to the sensitivity and volume of the information, the purposes for which it is used, and the format in which it is stored, including
- Internal policies and procedures that define the roles and responsibilities of our employees throughout the life cycle of Personal Information and limit access to that information on a “need-to-know” basis;
- If information is collected or stored electronically, technical security measures such as encryption, firewalls, anti-virus software and similar measures are used;
- The designation of a Privacy Officer who is accountable for Jurismedia’s compliance with applicable privacy laws;
- Offering employee privacy and computer security trainings;
- Procedures for receiving, investigating, and responding to complaints or inquiries regarding Jurismedia’s Personal Information handling practices, including any privacy incidents involving Personal Information;
- A governance framework governing the retention and destruction of Personal Information, as described in more detail below in the section How long do we keep your Personal Information?
- Contractual protections and other measures to ensure that service providers with whom we share Personal Information maintain reasonable protections and security standards. For example, we generally require our service providers to limit their use and retention of Personal Information to that which is necessary to provide their services and to notify us in the event of an actual or suspected privacy incident.
9. How long do we keep your Personal Information?
We retain your Personal Information only for as long as is reasonably necessary or appropriate to fulfill the purposes identified in this Policy, or as permitted or required by law. We may retain certain Personal Information for a longer period of time, even if you are no longer our customer (for example, for tax and financial record keeping, security, fraud prevention and business management). Once such Personal Information is no longer needed, your Personal Information will be securely destroyed or de-identified in accordance with applicable laws.
10. Transborder transfers of Personal Information
Your Personal Information may be transferred to, stored, accessed, or used in a jurisdiction other than your home jurisdiction (for example, outside of Quebec or Canada) in connection with our use of service providers we have engaged. We engage these service providers to help us provide our services to you, for example, to process payments, fulfill product orders, provide e-commerce functionality or manage our communications with you.
We make every effort to ensure that all of our service providers take reasonable security measures to protect your Personal Information (this includes technical, administrative and physical safeguards to protect your Personal Information). We make every effort to ensure that our service providers only use your Personal Information for the authorized purposes we have disclosed to you or as otherwise permitted by applicable law.
When Personal Information is transferred outside of Quebec or Canada, it is subject to the laws of the foreign jurisdiction, which may differ from those of your jurisdiction, and any Personal Information transferred to another jurisdiction will be subject to the law enforcement, regulatory and national security authorities of that jurisdiction. Subject to such laws, we will use contractual measures to the best of our ability to maintain protections for your Personal Information that are at least equivalent to those that apply in Canada.
11. Access and correction of your Personal Information
You may have the right to access and request correction of your Personal Information if it is inaccurate, incomplete, or outdated, subject to limited exceptions under applicable law.
To access and correct your Personal Information, please contact Us in writing using the appropriate contact information in the Contact Us section below.
12. Changes to this Policy
We may make changes to this Policy from time to time. The changes we make will be effective when we post an amended version of the Policy on our website. If the changes we make are material, we will provide more prominent notice when required by applicable law. Your continued use of our services or purchase of our products after we post or update the Policy will constitute your acceptance of the changes to the Policy. If you do not agree with the changes to our Policy, it is your responsibility to stop using our services or purchasing our products. It is your responsibility to ensure that you read, understand and accept the latest version of the Policy. The “Effective” date at the top of the Policy indicates the date it was last updated.
13. Emails sent via OAut2
You as a user of Margill may decide to use your Gmail, Google Apps (G Suite) or Microsoft (Outlook, Hotmail, Office 365) accounts with Google’s or Microsoft’s preferred authentication method, called OAut2 to send emails to your customers via Margill. When using OAut2 for Gmail or Microsoft email accounts, Margill will not be able to see, store, or transmit your account’s password. Instead, it will use a so-called “access token” to log in. This access token uses complex math (cryptography) and cannot be used to recover the account’s password, even if the token is intercepted by a malicious third party.
After you log in to Gmail or Microsoft, Margill will need permissions to allow you to “Send email on your behalf”. This authorization sends emails that appear to have been sent by you (i.e., from your email address).
14. Information for individuals in the United Kingdom and the European Union
Jurismedia Inc. acts as a data controller when determining the purposes and means of processing Personal Information. This is primarily in relation to contact information of customers who use Margill Finance softwares, and for Personal Information that may be processed on its website. Jurismedia also acts as a processor of Personal Information on behalf of the data controllers who use Margill software and who enter Personal Information into that software hosted on cloud services.
Legal basis for processing Personal Information
Jurismedia may process the Personal Information of its customers and the Personal Information provided by its customers under the following legal bases:
- We have a legitimate interest in processing your Personal Information, such as fighting fraud, or improving our services. You have the right to object to such processing as explained in the Your rights section below;
- If we have a contract with you and your Personal Information or the Personal Information provided is necessary for the performance of the contract, for example to process payment for services;
- We must comply with a legal or regulatory obligation, for example a court order may require us to disclose your Personal Information or information hosted on cloud services.
Individuals in the European Union and the United Kingdom have certain rights in relation to their Personal Information, which vary depending on the processing activities undertaken, and which are also subject to certain exceptions.
Right to withdraw consent
You may withdraw your consent at any time, subject to legal or contractual obligations, and the provision of reasonable notice.
Right of access, correction, and deletion of your Personal Information
You have the right to request access to the Personal Information that we hold about you as well as the following information: (i) the purposes of the processing, (ii) the categories of Personal Information involved, (iii) the recipients or categories of recipients to whom the Personal Information has been or will be disclosed, especially recipients who are outside of Canada, the European Union or the United Kingdom, (iv) the length of time the Personal Information is retained or the criteria used to determine the length of time it is retained, (v) the existence of the right to request rectification or erasure of Personal Information, to object to processing, to request limiting the processing of Personal Information, (vi) the right to lodge a complaint with a supervisory authority, (vii) the source of the Personal Information.
You also have the right to request the erasure of your Personal Information. However, we will not comply with this request if the processing of your Personal Information is necessary for us to comply with a legal obligation or to enable us to defend or exercise our legal rights.
You have the right to request the restriction of the processing of your Personal Information in the following circumstances: (i) you challenge the accuracy of the Personal Information, (ii) the processing is unlawful, but you require the use of your Personal Information to be limited, (iii) we no longer have any reason to continue processing your Personal Information, but you need the Personal Information for the establishment, exercise or defence of legal claims, (iv) you have objected to the processing of your Personal Information and so the processing of your Personal Information is limited while we verify whether our legitimate reasons for processing your Personal Information outweigh yours.
We may continue to process your Personal Information following a request to restrict processing: (i) if we have your consent, (ii) to establish, exercise or defend our legal rights, (iii) to protect the rights of another natural or legal person.
Right to portability
To the extent that we process your Personal Information based on your consent or pursuant to a contract, you have, by way of automated processes, the right to receive your Personal Information that you have provided in a structured, commonly used and machine-readable format, and have the right to request the transfer of that Personal Information to another controller.
Right to object to the processing of your Personal Information
You may object to the processing of your Personal Information, on grounds relating to your particular situation, where the legal basis for our processing of Personal Information is legitimate interest. We may continue to process your Personal Information if we demonstrate compelling legitimate grounds for the processing that override your interests and rights and freedoms, or for the establishment, exercise or defence of legal claims.
Right to complain to your supervisory authority
You have the right to complain to your local supervisory authority if you have any concerns about our processing of Personal Information.
We would appreciate it if you would contact us in advance to resolve any problems, although you may contact your supervisory authority at any time.
How to exercise your rights
If you wish to exercise your rights, you may contact us by referring to the following section. If we are processing your Personal Information on behalf of one of our clients, we will refer you to that client.
Before processing your request, we may ask you for certain information to confirm your identity for security reasons. We reserve the right to charge you a fee where permitted by law, and if your request is clearly unfounded or excessive. We may also refuse to comply with your request.
International transfer of Personal Information
We may use the services of service providers located outside of Canada in countries that do not benefit from an adequacy decision issued by the European Commission, or the competent authority in the United Kingdom. In this case, we will ensure that appropriate safeguards such as standard data protection clauses adopted by the European Commission or the competent authority in the UK are in place.
15. Contact us
If you have any questions or complaints about how we handle your Personal Information, please contact us at the coordinates listed below:
Jurismedia’s Privacy Officer
75 boulevard des Châteaux, bureau 102