1. INTRODUCTION

Thank you for using the Punchcard Systems Inc. website (the “Site”). This Privacy Policy describes how Punchcard Systems Inc. (“us”, “we”, or “our”) collects, uses and discloses the personal information of visitors and other users of the Site (collectively, “users”, “you” or “your”) and clients, industry partners and other parties with whom we have entered into written contracts (collectively, “Contracting Parties”). All collection, use and disclosure of your personal information by us within the Province of Alberta is carried out in accordance with the Personal Information Protection Act (Alberta) (“PIPA”). All collection, use and disclosure of your personal information by us that occurs across provincial borders but within Canada is carried out in accordance with the Personal Information Protection and Electronic Documents Act (Canada) (“PIPEDA”). We also comply with applicable privacy laws in other jurisdictions as discussed below. Please read this Privacy Policy carefully prior to using the Site.

2. CONTRACTING PARTIES

Rights governed by contract. Our rights and obligations with respect to the personal information of Contracting Parties are governed by the relevant contract(s) between us and each Contracting Party and applicable law. Specific rights and obligations pertaining to collection, use and disclosure of any personal information in the course of a contractual relationship are subject to the relevant contract, and in the event of any inconsistency between such contract and this Privacy Policy, the terms of the contract will prevail and control.

Retention. Personal information of Contracting Parties will be retained only for as long as necessary to fulfill the purposes for which it was collected unless explicitly stated otherwise in the contract.

Proprietary rights. The personal information shared by Contracting Parties under the terms of any contract shall remain the property of the respective Contracting Party unless explicitly stated otherwise in the contract. 

Safeguards. We commit to implementing appropriate technical, administrative, and physical safeguards to protect personal information obtained from Contracting Parties, as outlined in the applicable contract and required by law.

3. CONSENT

By using our Site or purchasing software products or related services from us (our “Products and Services”), you consent to our processing of your personal information in accordance with this Privacy Policy. If you do not consent, we may not be able to offer you our Products and Services. Your consent to our processing of your personal information can be withdrawn by following the directions in the “Your Rights” section below. Withdrawing your consent may impact our ability to offer you our Products and Services. Please note that we may collect certain personal information without consent where required by applicable law.

4. TYPES OF PERSONAL INFORMATION COLLECTED

Information that you provide to us. We collect the personal information you provide when you: (a) purchase our Products and Services; or (b) request information through the “Contact Us” page of the Site or via e-mail. The personal information that must be provided when you “Contact Us” includes first name, last name, company (optional), job title (optional), email address and phone number (optional).

Analytics information. We may automatically collect certain types of information whenever you visit the Site, including (without limitation): Google Analytics data, page(s) visited, time spent on page(s), time zone, web browser information, country of origin, click-stream data, IP address, internet service provider, browser, the date and time of your visit, the documents downloaded, search activity, and referring URL.

Information relating to communications. When you open emails from us, we may receive confirmation noting you opened an email. We may keep track of the emails we send you. Additionally, we keep a record of what types of emails you have opted to receive and not to receive to ensure that we only send you emails that you wish to receive.

5. HOW PERSONAL INFORMATION IS COLLECTED

Information that you provide to us. We collect this type of personal information directly from you. While all such information is provided voluntarily, certain information is required to purchase Products and Services.

Site usage. We track usage patterns on the Site automatically. Each time you visit our Site, our server may record the Site usage information listed in Section 4, “Analytics Information”.

Cookies. We may also employ, on an opt-in basis, “cookies” (a string of information that a Site stores on a visitor’s computer, and that the visitor’s browser provides to the Site each time the visitor returns) or similar technologies that provide additional functionality to the Site and helps us analyze Site usage more accurately. Cookies allow for a personalized experience when you visit or revisit the Site. Site users who do not wish to have cookies placed on their computers may opt out of using the consent management tool incorporated into our Site or by setting their browsers to refuse cookies before using the Site. Certain Site features may not function properly if your browser blocks cookies.

6. PURPOSES OF COLLECTION, USE AND DISCLOSURE

Providing and administering our Products and Services. The provision of Products and Services by us to you requires collection, use and disclosure of certain personal information. 

Communicating with you. Your personal information will be collected, used and disclosed for the purposes of: (a) responding to your voluntary communications to us; and (b) providing newsletters and other company information directly to you when you have signed up for direct communications. Your personal information may be shared internally for the purposes set out above. 

Providing, administering and improving the Site. Certain non-sensitive, anonymized and aggregated information may be collected and used for the purpose of improving the Site.

Making content and resources available to users of the Site. Certain non-sensitive, anonymized and aggregated information may be collected and used for the purpose of content and resource creation. Once again, your sensitive personal information will not be used for this purpose.

7. USE OF PERSONAL INFORMATION

We use your personal information for the purposes of providing, administering and improving our Products and Services. The personal information that you voluntarily provide to us is used solely in connection with the provision of our Products and Services. Personal information that we collect automatically may be used for certain ancillary purposes, including (without limitation) providing, administering and improving the Site and making content and resources available to users of the Site. In all circumstances, your personal information will only be used for the purpose(s) for which it was collected.

8. DISCLOSURE OF PERSONAL INFORMATION

We may share your personal information only pursuant to applicable laws, court orders, or legal process, which may occur with or without notice to you.

9. PROTECTION OF PERSONAL INFORMATION AND BREACH OF SAFEGUARDS

Security measures. We have implemented appropriate technical and organizational security measures against loss or unlawful processing of your personal information. We use standard, industry-wide, commercially reasonable security practices to protect your information. 

Disclaimer. As effective as our practices are, no security system is impenetrable. We cannot guarantee the security of all personal information, nor can we guarantee that information you supply will not be intercepted while being transmitted to us over the Internet. Any transmission of information by you to us is at your own risk. 

Security breach. In the event of a security breach involving your personal information, if there is a risk of significant harm to you or any other individual, we will promptly report the breach as required by applicable law.

10. RETENTION OF PERSONAL INFORMATION

If you do not request continued retention of your personal information, we will destroy, erase or anonymize such information when it is no longer required (a) to comply with a legal obligation; (b) to pursue our legal rights and remedies; or (c) for any other purpose identified in this Privacy Policy.

We may retain certain aggregated, non-identifying information indefinitely for evaluation, reporting and statistical analysis related to our Products and Services.

11. MARKETING

You may opt-in to receive marketing communications from us. If you opt-in to receive marketing communications from us, we may use your contact details to send you general updates regarding our news and our Products and Services. You may opt-out of receiving these updates at any time by following the opt-out instructions in the communication.

12. YOUR RIGHTS

Right to access. Upon request, you will be informed of the existence, use and disclosure of your personal information that is under our custody and you will be given access to such personal information. 

Right to correction. You may challenge the accuracy and completeness of your personal information under our custody and request that it is amended as appropriate. 

Withdrawal of consent and erasure. You may withdraw your consent to the collection, use or disclosure of your personal information, request erasure of your personal information or object to our processing of your personal information. In such circumstances, we may no longer be able to provide our Products and Services to you.

Any requests or directions with respect to your personal information should be provided to our Privacy Officer using the “Contact Details” section below.

13. OTHER

External links. This Privacy Policy applies only to the Site and not to any advertisers, sponsors or other third-party websites which may be linked. We have not reviewed all of the Sites linked to the Site and we are not responsible for the contents of any such linked Sites. These other Sites may or may not have their own published privacy policies. If you visit a Site that is linked to the Site, you should review that Site’s privacy policy before providing any personal information. The inclusion of any link does not imply endorsement by us. Use of any such linked web site is at your own risk.

Governing law. This Privacy Policy, the subject matter of herein and all related matters will be governed by, and construed in accordance with, the laws of the Province of Alberta and the laws of Canada applicable therein.

Changes to this Privacy Policy. We may update this Privacy Policy from time to time to reflect changes to our information practices. Your continued use of the Site or purchase of products or services constitutes your ongoing agreement to this Privacy Policy, as updated or amended. We encourage you to periodically review this page for the latest information on our privacy practices.

14. CONTACT DETAILS

If you have questions, comments or concerns regarding our Privacy Policy, or if you’d like to exercise your rights with respect to your personal information, you can reach out to our Privacy Officer:

Name: Liza Gulezian

Address: #201 10414 103 Ave NW, Edmonton AB T5J 0J1

Phone: 780-306-4000

Email: liza.gulezian@punchcard.io

You can also contact us through the “Contact Us” page available on the Site. 

If you are not satisfied by our response, you can contact the Privacy Commissioner of Alberta or Canada:

Office of the Information and Privacy Commissioner (Edmonton)

#410, 9925 – 109 Street NW

Edmonton, AB     T5K 2J8

Office of the Privacy Commissioner of Canada

30 Victoria Street

Gatineau, Quebec, K1A 1H3