GhostPractice Inc. (“GhostPractice”, “we”, “our”, “us”) recognizes the importance of your right to privacy and wants you to be familiar with how we collect, use and disclose any personal information that individually identifies you and our commitment to meet our obligations under applicable Canadian privacy laws.
- What Personal Information do we collect?
Personal information means any information about an identifiable individual. Anonymous data means data that is not associated with or linked to any individual’s personal information or will not easily permit the identification of individuals (“Anonymous Data”). GhostPractice does not consider personal information to include Anonymous Data. The types of personal information that we may collect include, but is not limited to:
- your name;
- your physical address (including postal address);
- your email address;
- your payment information;
- your telephone number;
- your IP address; and
- personal information you give us that we did not request (such as personal information you voluntarily put into an email to us).
Purposes for Collecting Your Personal Information
We collect, use and disclose your personal information in order to provide you with our Products. We also collect, use and disclose your personal information to comply with legal and regulatory requirements and as otherwise may be permitted or required by applicable law. We will only use the personal information that we collect for the purposes for which it was collected. We collect your personal information for the following purposes and in accordance with applicable law:
- when you complete your registration process for certain Products;
- to provide you with our Products;
- to authenticate your identity when using the Products and for account billing purposes;
- to establish and maintain commercial relations with you, including responding to your questions;
- to respond to questions that you send by email or through our Site;
- to contact you about the Products, including notifying you about updates;
- if you are using the xchangedocs Product as a document and information sharing platform, to store, process, transmit and exchange documents, pictures, spreadsheets, videos and the like with co-participants in a legal matter (“Your Artefacts“);
- subject to applicable law, to notify you about other services and events provided by GhostPractice, which may be of interest to you;
- to customise the appearance of the Site and Products displayed to you;
- to obtain your feedback regarding our Products, including our surveys;
- to track behavioural information on the Site to serve similar content upon future visits;
- to improve the Site and Products and help us develop new services, apps, tools and Site features;
- to support our business functions such as internal business processes, marketing and advertising; and
- to meet any legal or regulatory requirements.
- When Do We Collect Personal Information?
We may collect your personal information when you voluntarily provide it to us by using our Site and Products or from third party sources. For example, we may ask you to provide personal information if you:
- use our Site and our Products;
- register, update or create an account on our Site and our Products;
- sign into your account;
- send us a question or comment by email or phone;
- post comments or other content on our Site and our Products;
- register to updates about our Products; and
- otherwise participate in features of our Site and our Products that ask for personal information.
We also collect information from the devices that you use to access xchangedocs. This includes IP addresses and the type of browser and device you use and certain identifiers associated with your devices. Your devices may also transmit location information to xchangedocs.
- Limiting Collection of Personal Information
- Use, Disclosure and Retention of Personal Information
We may generate Anonymous Data from personal information collected through the Site and Products by removing information that makes the data personally identifiable to an individual. Such Anonymous Data includes, but is not limited to, information we collect from your use of our Site and Products. For example, if you use the xchangedocs Product, we also collect usage information related to how you use xchangedocs, including actions taken such as uploading, sharing, downloading and viewing Artefacts. We use this information to facilitate ongoing improvements and enhancements to xchangedocs. We also collect information from the devices you use to access xchangedocs. We may use this Anonymous Data and aggregated data for any reasonable purpose subject to applicable law.
We retain your personal information only for as long as we need it to fulfill the purposes for which it was collected, to ensure your compliance with our Terms of Service, and to comply with our legal obligations.
We may also disclose your personal information in the following limited circumstances:
- when necessary to protect our safety, property or other rights, our representatives, customers and users of the Site, including to detect and prevent fraud;
- with your consent; or
- when otherwise required or permitted by law.
- Location of Personal Information
As discussed above, we may engage Third Parties to perform certain services on our behalf and to otherwise provide the Products. We have taken commercially reasonable steps to require that these Third Parties store and process personal information on servers located in Canada.
- Cookies, Web Beacons and Other Similar Technology
As you interact with this Site, we may use automatic data collection technology and services that record and collect information that identifies your computer, tracks your use of this Site and collects certain other information about you and your surfing habits. This data collection technology may include cookies, web beacons and other similar devices on this Site to enhance functionality and navigation for our visitors.
A cookie is a small data file that is placed on the hard drive of your computer so that your computer will “remember” information when you visit a site. Web beacons and tags are small strings of code that are used in conjunction with a cookie and allow us to record activity on our Site. Internet tags, graphic tags and similar web beacon type functions allow us to count the number of users who have visited a particular web page or to access certain cookies. We may use web beacons on this Site to count users and to recognize users by accessing our cookies. Being able to access our cookies allows us to personalize this Site and improve your experience at our We may also include web beacons in HTML-formatted e-mail messages that we send to determine which e-mail messages were opened. Information tracked through these mechanisms includes, but is not limited to: (i) your IP address; (ii) the type of web browser and operating system being used; (iii) the pages of the Site a user visits; and (iv) other sites a user visited before visiting our Site.
We may also employ cookies and action tags (also known as single pixel gifs or web beacons) to collect information about your use of, and activities on, our Site for our use but also for use by third parties that serve advertisements about GhostPractice on other sites you may visit. For instance, we may use Third Party programs/services, such as AdWords run by Google Inc. (“Google”) to serve advertisements on our behalf across the Internet. These Third Party program/services may collect information about your visits to our Site. In addition to the information about your visits to our Site, Third Parties may also use the information about your visits to other sites to target advertisements for services available from GhostPractice.
You can set your internet browser up so that you are notified when cookies are stored, you can decide in each individual case whether you want to accept cookies, or you can refuse to accept any cookies. However, if you do not accept cookies, you may be restricted in how you are able to use our Site. You can delete cookies that are already stored on your hard disk at any time. You will find more details on how to do this in the operating guide for your Internet browser program.
We maintain technical, physical and administrative security safeguards to protect your personal information against loss, theft, and unauthorized access. Any personal information that you provide to us is exchanged on a secured server. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we are committed to protecting your personal information, we cannot ensure or warrant the security of any information you provide to us.
We take reasonable steps to verify your identity before granting you access to your account on our Site, however, you are solely responsible for maintaining the secrecy of your username, password and any other account information. We also take reasonable steps to ensure that our employees are aware of the importance of maintaining the confidentiality of personal information and that unauthorized persons do not gain access to personal information that we have disposed of or destroyed.
- Individual Access and Accuracy of Personal Information
You may request access to your personal information which we may hold by contacting us at the contact information set forth below, and we will respond within the time periods provided for under applicable law. We will need to verify your identity before providing you with the personal information we hold about you. There is no cost for such access request unless you require copies of records. We may not be able to provide you with access to your personal information if the information cannot be separated from the personal information of others, cannot be disclosed for reasons of security or commercial confidentiality, or is protected by legal privilege. If we cannot provide you with access to your personal information, we will advise you of the reasons access is being denied, unless we are prohibited by law from doing so.
You may request to update and change your personal information at the contact information set forth below. We will endeavor to correct or complete any personal information which you advise us is inaccurate or incomplete. Where appropriate, the amended information will be transmitted to third parties having access to such information.
If you are using the xchangedocs Product, you can erase or delete at any stage, all or some of your Artefacts in your xchangedocs account through your operation of the software.
- Electronic Communications
As part of signing up to receive the Products, you may have also opted in to receive email communications from us. If you opted-in to receive such communications, we may use the information to: communicate with you regarding our products, Products and promotions; provide you with other information that you request; and/or improve our product and service offerings.
You will always have the opportunity to “unsubscribe” from receiving any of our e-mail or other communications at any time and we will ensure that our e-mails include instructions on how to unsubscribe if you no longer wish to receive future e-mails from us. We provide an on-going opportunity to unsubscribe or opt-out of contact by us by accessing our Site or by e-mail to firstname.lastname@example.org or at the following telephone number: 1-800-340-3234, extension 301.
- How to Contact Us
- see your personal information that you have already sent us so that you can correct, update or delete it from our files;
- ask that we not send you electronic communications or otherwise contact you; or
Please contact us at email@example.com or at the following telephone numbers: 416-363-1650 or 1-800-340-3234, extension 301 and we will endeavour to get back to you promptly. You may also wish to write us at the following address:
8 King Street East, Suite 1200
Attention: Privacy Officer