PRIVACY & ETHICS POLICY
Last Updated September 14, 2023
Diversified Communications, ULC. and its products and services (the “Company”) connect, educate and strengthen business communities through market-leading events, and digital products. This Privacy Policy (“Policy”) describes our general privacy policy and practices in relation to Company’s websites, events, and services (collectively, the “Services”).
Company values the trust that you place in us by letting us act as custodians of your data. We take our responsibility to protect and secure your information seriously and strive for transparency around our information security program, including our practices for protecting and handling that information, further detailed within this Policy.
In compliance with international data privacy laws this policy serves as Company’s Global Data Protection Regulation (“GDPR”) Data Collection and Processing Notice.
1. APPLICABILITY
This Policy applies to individuals who engage in Company Services, including registration, attendance, exhibiting, sponsoring, and consumption of and/or creation of content in any format as well as third party service providers that Company relies on to produce Company Services, including vendors, partners and sponsors (collectively, “Customers”).
2. DATA PROTECTION RIGHTS UNDER GDPR
A. For the purpose of this Privacy Policy, we are a Data Controller of your personal information. If you are and EU Person), our legal basis for collecting and using your personal information, as described in this Privacy Policy, depends on the information we collect and the specific context in which we collect it. We may process your personal information because:
i. We need to perform a contract with you, such as when you use our services You have given us permission to do so
ii. The processing is in our legitimate interests and it’s not overridden by your rights
iii. For payment processing purposes
iv. To comply with the law
ii. The processing is in our legitimate interests and it’s not overridden by your rights
iii. For payment processing purposes
iv. To comply with the law
B. If you are a EU Person, you have certain data protection rights Including the following:
i. The right to access, update or to delete the personal information we have on you
ii. The right of rectification
iii. The right of restriction
iv. The right to data portability
v. The right to withdraw consent.
ii. The right of rectification
iii. The right of restriction
iv. The right to data portability
v. The right to withdraw consent.
C. Please note that we may ask EU Persons to verify your identity before responding to such requests.
D. EU Persons have the right to complain to the Data Protection Authority in your European Economic Area about our collection and use of your personal information and data.
E. EU Persons who wish to exercise their data protection rights can do so by accessing our Data Request Portal.
3. INFORMATION COLLECTED — CATEGORIES OF INFORMATION
Information that the Company collects falls in to one of the following categories:
Information that the Company collects falls in to one of the following categories:
A. Information About You — this includes personally identifiable data (“Personal Data”) as well as location data based on when and where you interact with Company Services
B. Activity Information — this includes information related to things you did (e.g. registration, attendance, purchases, content read/watched, etc.) and may or may not be identifiable to your activity. In some cases, Company may receive and store certain non-identifiable information such as information collected passively using various technologies (e.g. visits to a webpage, etc.).
C. Aggregated or De-Identified Data —Company may aggregate and/or de-identify information collected by the Company Services or other means so that the information is not intended to identify you. This Policy does not restrict our use or disclosure of aggregated and/or de-identified information
i. Photography and Video: As part of marketing and fulfilling Company Services, Company may take photos and/or videos of attendees, exhibitors and faculty. These photos and videos may be used in marketing materials. Should you wish for an identifiable photo of you, not to be used for any purpose, you must advise Company in writing as directed below.
4. INFORMATION COLLECTED — METHODS OF COLLECTION
How we collect and store information depends on the Company Services in which you participate and use. Information Collected may come from one or more of the following methods:
How we collect and store information depends on the Company Services in which you participate and use. Information Collected may come from one or more of the following methods:
A. Information You Provide: Company collects information when you voluntarily choose to provide such information, such as when you contact Company with inquiries or utilize Company Services. By voluntarily providing Company with Personal Data, you are consenting to Company’s use of it in accordance with this Policy. If you provide Personal Data, you acknowledge and agree that such Personal Data may be transferred from your current location to the offices and servers of Company and authorized third parties herein for the purposes described in this Policy.
B. Information From Others: We may obtain information about you or activity information from third-parties, such as service providers, marketers, partners, researchers, and other Customers. Information obtained from any third-party source will only be used in accordance with this Policy. If you access the Company Services through a third-party connection or log-in, you authorize Company to collect, store, and use, in accordance with this Policy, any and all information available to Company through the third-party interface.
C. Information We Collect As you interact with Company Services, Company will collect and derive information about you and/or your activity. Company has multiple ways in which it collects this information:
i. Automatically-Collected Information
Company may automatically collect certain information about the computer or devices that are used to access the Company Services, as well as information about the apps, browsers or mobile devices used, through commonly-used information-gathering tools, such as cookies and web beacons (“Website Navigational Information”). Website Navigational Information includes standard information from your browser or device (such as browser/device type and language), your Internet Protocol (“IP”) address, and the actions you take on Company’s websites, such as the pages viewed and the links clicked. We may also collect and analyze information such as: (i) location information, unique device identifiers and other information about your mobile phone or other mobile device(s), browser types, browser language, operating system, the state/province or country from which you accessed the Company Services; and (ii) information related to the ways in which you interact with the Company Services, such as referring and exit pages and URLs, platform type, the number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used the Services, error logs, and other similar information. As described further below, we may use third-party analytics providers and technologies, including cookies and similar tools, to assist in collecting this information.
Company may automatically collect certain information about the computer or devices that are used to access the Company Services, as well as information about the apps, browsers or mobile devices used, through commonly-used information-gathering tools, such as cookies and web beacons (“Website Navigational Information”). Website Navigational Information includes standard information from your browser or device (such as browser/device type and language), your Internet Protocol (“IP”) address, and the actions you take on Company’s websites, such as the pages viewed and the links clicked. We may also collect and analyze information such as: (i) location information, unique device identifiers and other information about your mobile phone or other mobile device(s), browser types, browser language, operating system, the state/province or country from which you accessed the Company Services; and (ii) information related to the ways in which you interact with the Company Services, such as referring and exit pages and URLs, platform type, the number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used the Services, error logs, and other similar information. As described further below, we may use third-party analytics providers and technologies, including cookies and similar tools, to assist in collecting this information.
ii. Cookies
This Section describes our practices with respect to how we use cookies. By using Company Services with your browser set to accept cookies, you are consenting to our use of cookies in the manner described herein. We may collect data about your use of Company Services through the use of cookies, Internet server logs, tracking pixels (also called web beacons) and similar technologies. A cookie is a small text file that is placed on your computer or mobile device when you visit a website, that enables us to recognize your computer/device, store your preferences and settings, enhance your user experience by delivering content specific to your interests, perform searches and analytics, and assist with security administrative functions. An Internet server log is a file where website activity is stored. Server logs are used to track usage and provide security. A tracking pixel, which is also referred to as a web beacon or a clear GIF, is an electronic tag with a unique identifier that is embedded on webpages, in online advertisements and/or email. These pixels are designed to provide usage information, such as advertising impressions or clicks, measure popularity of the Services and associated advertising, and access user cookies.
This Section describes our practices with respect to how we use cookies. By using Company Services with your browser set to accept cookies, you are consenting to our use of cookies in the manner described herein. We may collect data about your use of Company Services through the use of cookies, Internet server logs, tracking pixels (also called web beacons) and similar technologies. A cookie is a small text file that is placed on your computer or mobile device when you visit a website, that enables us to recognize your computer/device, store your preferences and settings, enhance your user experience by delivering content specific to your interests, perform searches and analytics, and assist with security administrative functions. An Internet server log is a file where website activity is stored. Server logs are used to track usage and provide security. A tracking pixel, which is also referred to as a web beacon or a clear GIF, is an electronic tag with a unique identifier that is embedded on webpages, in online advertisements and/or email. These pixels are designed to provide usage information, such as advertising impressions or clicks, measure popularity of the Services and associated advertising, and access user cookies.
5. INFORMATION COLLECTED — PURPOSE
Company uses information collected in a manner that is consistent with this Policy. If you provide Personal Data for a certain reason, Company may use the Personal Data in connection with the reason for which it was obtained. For instance, if you contact Company by email, Company may use the Personal Data you provide to answer your question or resolved your problem. Also, if you provide Personal Data in order to obtain access to Company Services, Company will use your Personal Data to provide access to such services.
If you register for and/or use Company Services, Company will use your Personal Data to provide you with documents and other materials related to such Company Services. Company may also mail you documents and materials related to such Company Services as well as for other products and services that Company believes will be of interest to you.
Company may use your Personal Data, Activity Information and/or Aggregated/De-Identified Data to help Company improve Company Services, including content, user experience and online features/functions.
Company may use information it has collected about your location and/or preferences to customize recommendations of specific Company Services that may be of interest to you. If you access Company Services through a web or mobile device and you do not want your device to provide us with location-tracking information, you can disable the GPS or other location-tracking functions on your device, provided your device allows you to do this.
Company will not use information it has collected about you for any reason other than that specified within this Policy.
Company uses information collected in a manner that is consistent with this Policy. If you provide Personal Data for a certain reason, Company may use the Personal Data in connection with the reason for which it was obtained. For instance, if you contact Company by email, Company may use the Personal Data you provide to answer your question or resolved your problem. Also, if you provide Personal Data in order to obtain access to Company Services, Company will use your Personal Data to provide access to such services.
If you register for and/or use Company Services, Company will use your Personal Data to provide you with documents and other materials related to such Company Services. Company may also mail you documents and materials related to such Company Services as well as for other products and services that Company believes will be of interest to you.
Company may use your Personal Data, Activity Information and/or Aggregated/De-Identified Data to help Company improve Company Services, including content, user experience and online features/functions.
Company may use information it has collected about your location and/or preferences to customize recommendations of specific Company Services that may be of interest to you. If you access Company Services through a web or mobile device and you do not want your device to provide us with location-tracking information, you can disable the GPS or other location-tracking functions on your device, provided your device allows you to do this.
Company will not use information it has collected about you for any reason other than that specified within this Policy.
6. INFORMATION SHARING AND DISCLOSURE
Company considers your information to be a vital part of the relationship with you and protects it vigorously. There are, however; certain circumstances in which Company may share information it has collected with certain third-parties without notice to you, as set forth below:
Company considers your information to be a vital part of the relationship with you and protects it vigorously. There are, however; certain circumstances in which Company may share information it has collected with certain third-parties without notice to you, as set forth below:
A. Consent: If you consent to the disclosure, we may do so.
B. Event Sponsors: If you sign-up to attend an event or participate in an activity as part of Company Services, Company may share your information with companies involved in supporting the event or activity.
C. Service Providers: Company, like many businesses, sometimes hires other companies to perform certain business-related functions. As such and for business operations purposes only, we may provide access to your information to select third-parties who perform services for us such as registration, mailing, billing, sales, marketing, advertising, market research, fulfillment, data storage, transfer, analysis and processing, analytics, participation in a contest or sweepstakes, and legal services. When Company employs another company to perform a function of this nature, Company endeavors to ensure their security systems are compliant with applicable law and provides them only with the information they need to perform their specific function. Company also requires they limit their use of Personal Data accordingly.
D. Business Partners: From time to time, Company may offer you the opportunity to participate in discount plans and similar benefit programs from one or more of Company business partners. If you opt-in to participate in the discount plans or other benefit programs of Company business partners, Company will disclose your Personal Data to such business partners so that they may register you for the applicable discount and/or benefit program.
E. Business Transfers: We reserve the right to disclose and transfer all information collected about you, including, without limitation, your Personal Data, Activity Data, and Aggregated or De-Identified Data, to a successor (or potential successor) company in connection with a merger, acquisition, or sale of all, or components, of our business, or in connection with due diligence associated with any such transaction.
F. Protection of Company and Others: We may disclose any of your information to: (i) comply with legal process; (ii) enforce any agreements that you entered into with us; (iii) respond to claims that any content violates the rights of third parties; (iv) respond to your requests for customer service; and/or (v) the extent necessary for the purposes of the legitimate interests pursued by us or by the third party or parties to whom the data are disclosed, except where such interests are overridden by the interests for fundamental rights and freedoms of the data subjects. We may also disclose information to law enforcement agencies in emergency circumstances, where the disclosure of such information is consistent with the types of emergency disclosures permitted or required by law.
7. ONLINE ANALYTICS. ADVERTISING AND MARKETING
Company may use third-party web analytics services such as Google Analytics, Google Adwords and other third-party applications for Display Advertising, in order to advertise online via its “Remarketing” feature. Third-party vendors, including Google, may show our ads on sites across the internet. Company and third-party vendors, including Google, use first-party cookies (such as Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize and serve ads based on someone’s past visit to websites. You can opt-out of the Google Analytics Advertiser Feature we use, including through Ads Settings, Ad Settings for mobile apps, or any other available means through this link. To opt-out of Google Adwords advertising features, click here.
Company may also target advertising and/or marketing messages depending on preferences you choose to share with us. Those messages, in any form, may personalize content based on your interests. For example, you may see different content on our website in different areas based on information that you have shared with us or based on observations we have made regarding your previous usage.
We require advertisers and their advertisements to comply with all Federal (Canada) and local regulations regarding direct-to-consumer advertising. We reserve the right to reject any advertisement for any reason.
Company may use third-party web analytics services such as Google Analytics, Google Adwords and other third-party applications for Display Advertising, in order to advertise online via its “Remarketing” feature. Third-party vendors, including Google, may show our ads on sites across the internet. Company and third-party vendors, including Google, use first-party cookies (such as Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize and serve ads based on someone’s past visit to websites. You can opt-out of the Google Analytics Advertiser Feature we use, including through Ads Settings, Ad Settings for mobile apps, or any other available means through this link. To opt-out of Google Adwords advertising features, click here.
Company may also target advertising and/or marketing messages depending on preferences you choose to share with us. Those messages, in any form, may personalize content based on your interests. For example, you may see different content on our website in different areas based on information that you have shared with us or based on observations we have made regarding your previous usage.
We require advertisers and their advertisements to comply with all Federal (Canada) and local regulations regarding direct-to-consumer advertising. We reserve the right to reject any advertisement for any reason.
8. SECURITY
Company takes data privacy seriously and has a strong information security posture including several security safeguards such as physical, administrative (policies & procedures) and technical (access and audit controls) to protect your information and maintain data security. These safeguards vary based on the sensitivity of the information that we collect and store. Although we take appropriate measures to safeguard against loss, misuse and unauthorized access, disclosure, alteration or destruction of information, we cannot assure you that information that we collect will never be disclosed in a manner that is inconsistent with this Policy.
Company takes data privacy seriously and has a strong information security posture including several security safeguards such as physical, administrative (policies & procedures) and technical (access and audit controls) to protect your information and maintain data security. These safeguards vary based on the sensitivity of the information that we collect and store. Although we take appropriate measures to safeguard against loss, misuse and unauthorized access, disclosure, alteration or destruction of information, we cannot assure you that information that we collect will never be disclosed in a manner that is inconsistent with this Policy.
9. EXCLUSIONS
Company may provide bulletin boards, blogs, online comments or chat rooms through Company Services. Any personal information you choose to submit in such a forum may be read, collected, or used by others who visit these forums, and may be used to send you unsolicited messages. Company is not responsible for the personal information you choose to submit in these forums. All such information shall be deemed to be non-confidential and Company shall be free to reproduce, use, disclose, and/or distribute such information to others without limitation or attribution.
Customers, Visitors, and Attendees may elect to use Company’s referral program to inform friends about Company Services. When using the referral program, Company requests the friend’s name and email address. Company will automatically send the friend a one-time email inviting him or her to visit Company’s website, but will not add the friend to ongoing communications streams. In the case where Company posts a list of Customers and testimonials on its websites, Company will first obtain the consent of each customer prior to posting such information or testimonials.
Company may provide bulletin boards, blogs, online comments or chat rooms through Company Services. Any personal information you choose to submit in such a forum may be read, collected, or used by others who visit these forums, and may be used to send you unsolicited messages. Company is not responsible for the personal information you choose to submit in these forums. All such information shall be deemed to be non-confidential and Company shall be free to reproduce, use, disclose, and/or distribute such information to others without limitation or attribution.
Customers, Visitors, and Attendees may elect to use Company’s referral program to inform friends about Company Services. When using the referral program, Company requests the friend’s name and email address. Company will automatically send the friend a one-time email inviting him or her to visit Company’s website, but will not add the friend to ongoing communications streams. In the case where Company posts a list of Customers and testimonials on its websites, Company will first obtain the consent of each customer prior to posting such information or testimonials.
10. USERS FROM OUTSIDE THE UNITED STATES
Company Services are governed by the applicable Federal/State/Provincial/Territorial and local laws of the United States and Canada. If you are using Company Services from outside the United States or Canada, your information will still be transferred to, stored, and processed in our facilities, in the United States and Canada.
The data protection and other laws of other countries might be different from the laws of the United States and Canada. When we transfer the information of a resident of the United States or Canada globally we will take all reasonable steps to protect your information and will otherwise store and process your information in compliance with applicable laws.
Company Services are governed by the applicable Federal/State/Provincial/Territorial and local laws of the United States and Canada. If you are using Company Services from outside the United States or Canada, your information will still be transferred to, stored, and processed in our facilities, in the United States and Canada.
The data protection and other laws of other countries might be different from the laws of the United States and Canada. When we transfer the information of a resident of the United States or Canada globally we will take all reasonable steps to protect your information and will otherwise store and process your information in compliance with applicable laws.
11. LINKS TO OTHER WEBSITES
Company Services may contain links to third-party websites. We are not responsible for the privacy practices or the content of those third-party websites. Any information you provide via those services is subject to the applicable third-party privacy policies and is not covered by this Policy.
Company Services may contain links to third-party websites. We are not responsible for the privacy practices or the content of those third-party websites. Any information you provide via those services is subject to the applicable third-party privacy policies and is not covered by this Policy.
12. CHILDREN
Company Services do not target and are not intended to attract children under the age of 18. Company does not knowingly solicit personal information from children under the age of 18. Should we learn or be notified that we have collected information from users under the age of 18, we will immediately delete such personal information.
Company Services do not target and are not intended to attract children under the age of 18. Company does not knowingly solicit personal information from children under the age of 18. Should we learn or be notified that we have collected information from users under the age of 18, we will immediately delete such personal information.
13. NO RIGHTS OF THIRD-PARTIES
This Policy does not create rights enforceable by third-parties.
This Policy does not create rights enforceable by third-parties.
14. HOW TO CONTACT DIVERSIFIED COMMUNICATIONS ULC
If you reside in a location that has data privacy laws that provide you with rights to request information about the Personal Data that the Company collects about you, or allows you to request Company delete and/or not have the Company sell your Personal Data, please submit a formal Data Subject Access Request (DSAR) by clicking here.
If you have any questions, comments, or concerns regarding this Policy or Company’s privacy practices you may contact us as follows:
Attn: General Manager
Diversified Communications ULC
1101 Kingston Rd., Suite 310 | Pickering, ON, L1V 1B5
info@pri-med.ca | info@accountex.ca
If you reside in a location that has data privacy laws that provide you with rights to request information about the Personal Data that the Company collects about you, or allows you to request Company delete and/or not have the Company sell your Personal Data, please submit a formal Data Subject Access Request (DSAR) by clicking here.
If you have any questions, comments, or concerns regarding this Policy or Company’s privacy practices you may contact us as follows:
Attn: General Manager
Diversified Communications ULC
1101 Kingston Rd., Suite 310 | Pickering, ON, L1V 1B5
info@pri-med.ca | info@accountex.ca
15. CHANGES TO THIS POLICY
Laws, rules & regulations affecting data privacy change over time. As a result, Company reserves the right to update or modify this Policy at any time without prior notice. Please review this Policy periodically for changes, especially before providing Company with Personal Data. If Company makes material changes to this Policy which could be considered adverse to you, we will provide notification of the material adverse changes in accordance with applicable law.
Laws, rules & regulations affecting data privacy change over time. As a result, Company reserves the right to update or modify this Policy at any time without prior notice. Please review this Policy periodically for changes, especially before providing Company with Personal Data. If Company makes material changes to this Policy which could be considered adverse to you, we will provide notification of the material adverse changes in accordance with applicable law.