ETTRICS
PRIVACY POLICY

1. INTRODUCTION

Gardenbook Inc. o/a Ettrics (“Ettrics”, “we”, “us”) has created this Privacy Policy (“Privacy Policy”) in order to set out how we collect, use, and disclose personal information through our Ettrics Website located at https://Ettrics.com/ (the “Website”) and through the provision of cross-functional services of design, technology, marketing, and data creative and related applications, offered by Ettrics (the “Services”) (as identified on our Website) to our clients (“Clients”).


The privacy of our Clients is of great importance to us. By visiting our Website or using our Services in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy and you hereby consent to the collection, use and disclosure of your Personal Information in accordance with this Privacy Policy.


2. WHAT DOES THIS PRIVACY POLICY COVER?


This Privacy Policy covers our collection, use and disclosure of information about identifiable individuals and information, which can be used to identify an individual (“Personal Information”). Personal Information may be collected about visitors to the Website, and our Clients (“Customers”).


This Privacy Policy does not apply to the practices of companies that we do not own or control, including those practices of third party companies.  


3. COLLECTION AND USE OF PERSONAL INFORMATION 


3.1 Personally Identifiable Information.

When you register for the Services or inquire about engaging Ettrics, Ettrics collects certain Personal Information from you (collectively, “Personal Information”). In particular, Ettrics may collect your name, company name, email address, phone number, business address and/or billing information, such as credit card number and billing address. In addition, you may provide to us third party access to your accounts, such as hosting or application credentials.


We receive and store any information you enter on the Website, upload through our Website or from other third-party services that you link to your account (including, but not limited to Facebook and Twitter, Hubspot) or provide to us in any other way, including by e-mail. When you send an e-mail to Ettrics, we may retain your e-mail address and the contents of the e-mail you send.


Ettrics uses the Personal Information to provide and deliver the Services you request, to communicate with you about services, respond to your questions, provide updates on our services, and events, to provide thought leadership content, newsletters, and provide other news or information about us, for billing, to make improvements to our Website, and for other purposes which we will notify you about and seek your consent.


You can choose not to provide us with certain Personally Identifiable Information, but then you may not be able to take advantage of all of the services and products offered on the Site.

3.2 Non-Personally Identifiable Information

From time to time, we may also ask you to provide us with non-personally identifiable information, that is, data that is not intended to allow us to identify you personally. This information may be aggregated and used for our internal purposes. No third party is intended to be able to know who you are as a result of the use of this information.

We may also automatically collect Website usage information, such as the numbers and frequency of users accessing the Website, pages visited and similar data. This data is used in the aggregate, that is, as a statistical measure, and not in a manner that is intended to identify you personally. Aggregate information generally is collected through the use of cookies and web beacons. This aggregate information helps Ettrics determine general usage patterns and modify the Website in order to improve your experience. This type of aggregate information may be shared with third parties at any time.

In addition to our use of technologies as described herein, we may permit certain third party companies to help us tailor advertising that we think may be of interest to you based on your use of the Website and/or services and to otherwise collect and use data about your use of Website. The information that such advertisers use to perform these functions will be non-personally identifiable Information. 


4. STORAGE LOCATION AND TRANSFER OF PERSONAL INFORMATION


Ettrics processes and stores its data, including Personal Information, on servers located in Canada and the United States. Ettrics also transfers data to third-party service providers. 


By submitting Personal Information or otherwise using the Services, you agree to this transfer, storing or processing of your Personal Information in Canada and United States. You acknowledge and agree that your Personal Information may be accessible to law enforcement and governmental agencies in Canada and the United States under lawful access regimes or court order.


5. DISCLOSURE OF PERSONAL INFORMATION WITH THIRD PARTIES


Rest assured that we neither rent nor sell your Personally Identifiable Information to anyone and that we will share your Personally Identifiable Information only as described below.


5.1 Ettrics Personnel or Service Providers.

We may from time to time employ a person or a third party company to perform tasks on our behalf and we may need to share Personal Information with them to provide certain services. Unless we tell you differently, such persons or third parties do not have any right to use the Personal Information we share with them beyond what is necessary for them to provide the tasks and services on our behalf. 


5.2 Business Transfers.

If our business (or substantially all of our assets) are acquired by a third party, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information may be made available or otherwise transferred to the new controlling entity, where permitted under applicable law.


5.3 With Your Consent.

If we need to use or disclose any Personal Information in a way not identified in this Privacy Policy, we will notify you and/or obtain consent as required under applicable privacy laws.


5.4 As required by law.

We may disclose your Personal Information to third parties without your consent if we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, our Clients, or anyone else (including the rights or property of anyone else) that could be harmed by such activities. Further, we may disclose Personal Information when we believe in good faith that such disclosure is required by and in accordance with the law. 


We also reserve the right to access, read, preserve, and disclose any information as we reasonably believe is necessary to:


  • satisfy any applicable law, regulation, legal process or governmental request; 
  • enforce our contracts or user agreement, including investigation of potential violations hereof; and
  • detect, prevent, or otherwise address fraud, security or technical issues. 


The above may include exchanging information with other companies and organizations for fraud protection and spam/malware prevention. Notwithstanding the general terms of this policy, the collection, use, and disclosure of Personal Information may be made outside of the terms herein to the extent provided for in any applicable privacy or other legislation in effect from time to time, or pursuant to court orders.


6. RETENTION


We will keep your Personal Information for as long as it remains necessary for the identified purpose or as required by law, which may extend beyond the termination of our relationship with you. We may retain certain data as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personally-identifiable data, account recovery, or if required by law. All retained Personal Information will remain subject to the terms of this Privacy Policy.


7. RESIDENTS OF THE EUROPEAN ECONOMIC AREA (“EEA”)


Ettrics processes Personal Data where the processing is necessary for the performance of a contract with our Clients, where the individual has provided consent and otherwise where the processing is necessary for the purposes of the legitimate interests pursued by us or our Clients as data controllers.


When we process Personal Data on behalf of our Clients, we are acting as the data processor and our Client is the data controller.


If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Ettrics aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Information (known as “Personal Data” under the EU General Data Protection Regulation). You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA). 


If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us by emailing privacy@ettrics.com. Note that where we act as the data processor on behalf of our Clients, you will be required to contact the data controller directly to exercise your rights.


Please note that we may ask you to verify your identity before responding to such requests.



8. ACCESS, CORRECTION AND ACCURACY


You have the right to access the Personal Information we hold about you in order to verify the Personal Information we have collected in respect of you and to have a general account of our uses of that information. Upon receipt of your written request, we will provide you with a copy of your Personal Information, although in certain limited circumstances, and as permitted under law, we may not be able to make all relevant information available to you, such as where that information also pertains to another Client or individual. In such circumstances we will provide reasons for the denial to you upon request. We will endeavour to deal with all requests for access and modifications in a timely manner.


We will make every reasonable effort to keep your Personal Information accurate and up to date, and we will provide you with mechanisms to update, correct, delete or add to your Personal Information as appropriate. As appropriate, this amended Personal Information will be transmitted to those parties to which we are permitted to disclose your information. Having accurate Personal Information about you enables us to give you the best possible service.


9. CHANGES TO THIS PRIVACY POLICY


We may amend this Privacy Policy from time to time. Use of Personal Information we collect is subject to the Privacy Policy in effect at the time such information is collected, used or disclosed. If we make material changes or changes in the way we use Personal Information, we will notify you by posting an announcement on our Website or sending you an email prior to the change becoming effective. You are bound by any changes to the Privacy Policy when you use the Website or Services after such changes have been first posted.


10. ADDITIONAL INFORMATION


Questions regarding this Privacy Policy or Ettrics’s privacy practices should be directed to our Privacy Officer:


Privacy Officer

Ettrics

44 Byward Market Square Suite 220, Ottawa, ON K1N 7A2


Email Address: privacy@ettrics.com


Effective Date: Monday, January 18, 2021

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