This Privacy Policy explains how Sooof Inc. (“we”, “us”, “our” or “Sooof”) collects, uses and shares your “Personal Information” – information that identifies, relates to, describes or is capable of being associated with you as a particular individual, such as your name, address, email address or telephone number – and other data through your use of any of Sooof’s web sites, services, code and/or software (collectively, the “Services”).
By accessing the Services, you accept this Privacy Policy, agree to the terms, conditions and notices contained or referenced herein as well as in Sooof’s Terms of Service located at https://sooofinc.com/Home/EndUserTermsConditions (the “TOS”), and you consent to collection, use and disclosure of your Personal Information as described herein. Any capitalized term used, but not defined, herein, has the meaning given to it in the TOS.
As a general rule there are two categories of users of the Services: “Buyers” who are interested in opting-in to offers for products or services from Suppliers, and “Suppliers” who are in the business of offering products and services to Buyers (collectively, “you”).
What Information We Collect
We may collect two types of Personal Information: (i) personally identifiable information (“PII”), which constitutes any information that can identify an individual directly or through other reasonably available means and is otherwise referred to herein as “Personal Information”, but does not include information deemed not to be Personal Information in accordance with applicable law; and (ii) non-personally identifiable information (“Non-PII”), which is also referred to as aggregate and anonymous data, or is information that would not, in and of itself, identify you. Please note that what one may initially consider to be Non-PII may, in some contexts, such as in respect of small geographic locations or communities, result in such information being attributable to you or allowing you to be identified because of the context. Please consider this when providing information.
What Information We Ask You For
When you use the Services, you will be asked to provide us with certain PII and Non-PII about yourself such as your name, email, industry, role, title (optional) and, where applicable, certain banking information.
What Information We Automatically Gather
Sooof uses "cookies" to collect non-PII and information. Cookies are small text files a website uses to recognize repeat users, and is typically placed on your hard disk by a web page server. Cookies contain information that can later be read by a web server in the domain that issued the cookie to you. The way cookies function is by assigning a number to the user that has no meaning outside of the assigning website.
Such Non-PII may automatically be collected when you use or visit the Services. The cookies we employ collect and store information related to your use of the Services, such as the pages you view on the website, and information pertaining to your computer device, network, protocols and software and the date and time of your visit. This Non-PII we automatically collect is used to help us provide a more relevant and useful site experience to you. This information is also used in the aggregate to perform statistical analyses of user behavior and characteristics in order to measure interest in and use of the various areas of the Services.
What Other Information May Be Collected
Profile. As a Buyer or a Supplier, you may have a public profile (a “Profile”) on the Services and certain information in your profile may be available to other users of the Services. You have the ability to view your Profile, and can update and/or change your Profile by notifying us of any changes you wish to make. Note that if you include PII in your Profile, it can be used and viewed by others. We are not responsible for the information you choose to include in your Profile.
Third Party Services. As a Supplier or a Buyer, we may request access to your social media webpages such as Facebook and Twitter for purposes of your Profile. Some of those third party services may also provide us with Personal Information from your accounts and, as such, we may collect such information.
Feedback. You should feel free to give us feedback, register a complaint, or ask questions about the Services. We may store your communications, including any Personal Information you include in them, so that we can effectively respond to you.
How We Use Your Information
Our primary objective in collecting your information is to provide services that are of the greatest interest and use to you. In addition to those uses mentioned above, we use the PII collected for the following purposes: (i) for registration and access to your account; (ii) to manage your account; (iii) to communicate with you; (iv) to process payments; (v) to measure interest in and improve our Services; (vi) to provide you with information and offers from us or third parties that we believe you may find useful or interesting, including marketing or promotional materials, advertisements, coupons and other information on services and products offered by us or third parties; (vii) to resolve disputes troubleshoot problems; and (viii) to monitor the Services and to enforce the TOS. In addition, the Personal Information allows us to develop and customize the Services and to better understand what products and services you would like. The Personal Information may also be used to send you e-mails that we believe may be of interest to you, such as our newsletters. You may opt out of receiving any such e-mails by unsubscribing; simply follow the unsubscribing instructions.
In addition to the uses mentioned above, we use the Non-PII collection for the following purposes: (i) to monitor and analyze use of the Services and for the technical administration of the Services; (ii) to increase functionality and user-friendliness of the Services; (iii) to better tailor the Services to your needs; and (iv) to generate and derive useful data and information concerning the interests, characteristics and use behavior of users, and to verify that users of the Services meet the criteria required to process their requests.
How We Share Your Information
We may share you information with the following parties and/or for the following purposes:
Suppliers – As a Buyer, we may share your Personal Information with Suppliers in connection with any Offers you opt-in to through the Services. This information is shared to facilitate any Offers and the entry into Contracts.
Affiliates. We may share much of our data, including your PII, with our parent, subsidiary and other affiliated companies (each a “Related Entity”) that are committed to serving your online needs and providing related services.
Public Profiles. As mentioned above, if you provide Personal Information in your Profile, this information will be publicly available and therefore may be shared to other users of the Services.
Trusted Third Party Service Providers. We may use third parties to provide technical support and perform tracking and reporting functions, conduct quality assurance testing, and provide other services in connection with the Services. We may share Personal Information about you with them so that they can perform the services they are required to perform.
Other Third Parties. We may share information with other parties whom you ask us to send Personal Information, whether explicitly or by using the Services.
Aggregate Information. We may share non-PII in the aggregate to third parties relating to user behavior in connection with actual or prospective business relationship with those third parties. For example, we may disclose the number of users that have been exposed to, or clicked on, links.
Business Transfers. We reserve the right to disclose and/or transfer information about you to a third party in the event of an actual or proposed sale, purchase, lease, amalgamation, merger, joint venture or other type of disposition or financing of any or all of the Sooof Inc. or any of its assets or shares, in order to ensure that you continue to receive the same services. If another company acquires our company or all or substantially all of our assets, that company will assume the rights and obligations with respect to that information as described in this Privacy Policy.
Investigations. We reserve the right to investigate abuses on the Services, and enforce and apply our TOS and this Privacy Policy. We may disclose Personal Information about you to third parties if we have a good faith belief that such disclosure is reasonably necessary to: (i) take action regarding suspected illegal activities; (ii) enforce or apply our TOS and this Privacy Policy; (iii) comply with legal process and law enforcement instructions and orders, such as a search warrant, subpoena, statute, judicial proceeding, or other legal process served on us; or (iv) protect our rights, reputation, and property, or that of our users, affiliates, or the public.
How We Protect Your Personal Information
We understand how important protecting your privacy is, and we are committed to safeguarding the information you provide to us. And while we cannot guarantee absolute security, we have implemented specific security procedures to protect the storage and disclosure of your information, including the use of secure sockey layer (SSL) encryption technology. Further, access to your information is restricted to select employees or representatives.
How You Can Correct Your Information
To update your Personal Information, or please contact us at inquiries@sooofinc.com and notify us of what information is to be updated.
How Long We Keep Information
We keep the Personal Information you have given us for at least as long as you maintain your account with the Services. Keep in mind, however, that even if you delete your account, we may retain your Personal Information in conformance with our data retention policy, under which we may reasonably retain such information to comply with laws, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigations, enforce our TOS, and take other actions otherwise permitted by law.
External Links and Parties
If any part of the Services links you to other websites, those external websites do not operate under this Privacy Policy. We recommend that you examine the privacy policies posted on those other websites to understand their procedures for collecting, using, and disclosing personal information. Once you leave our website, our Privacy Policy will no longer apply. Also, we cannot guarantee the privacy of third parties whose information our users have provided to other members on the Website.
Canada’s Personal Information Protection and Electronic Documents Act
The Canadian government has enacted the Personal Information Protection and Electronic Documents Act (“PIPEDA”). PIPEDA outlines the way personal information may be used in Canada, and we fully adhere to it. You may at any time contact us regarding our use of your Personal Information by using the contact information referred to below or at the mailing address referred to below. You may contact us to provide you with more information in respect of our Privacy Policy and privacy practices, or to provide you with an opportunity to review your PII currently held by us and to request an amendment to the PII to correct any inaccuracies you determine are contained in such PII holdings. Where you demonstrate the inaccuracy or incompleteness of your PII held by us, we will correct or update the information as required. Please note that before we are able to provide you with any information or correct any inaccuracies we may ask you to verify your identity and to provide other details to help us to respond to your request. You are also entitled to request information as to the type of PII we have collected from you, how we have used your PII in the past and how we may use it in the future, and whether or not we have disclosed your PII to any third parties (and, if so, to whom).
There may be circumstances where we are unable to provide access to your PII. We may deny access for legally permissible reasons, such as situations where the information contains references to other individuals and is not reasonably severable, or where it cannot be disclosed for legal, security or other commercial proprietary reasons. We will advise you of any reason for denying an access request.
Privacy Officer
We are responsible for and will maintain and protect Personal Information in our possession or custody, including PII that we may transfer to third parties for processing. We have designated an individual or individuals who is/are accountable for compliance with this Privacy Policy.
To contact us concerning privacy issues, please send a letter to:
Attention: Privacy Officer
Sooof Inc.
70 University Avenue
Suite 1200
Toronto, ON
M5J 2M4
Email: inquiries@sooofinc.com
Changes to This Privacy Policy
We reserve the right to modify this Privacy Policy from time to time. We will notify our members of relevant changes by posting a notice on our website. The most current version of this Privacy Policy will govern our use of your information, and will always be located at https://sooofinc.com/Home/PrivacyPolicy By continuing to use our Services, you agree to be bound by the revised statement.
Hosting
The Services are hosted on Microsoft Cloud. Accordingly, please be advised that through your continued use of the Services, you may be transferring your Personal Information to countries other than your country of residence or jurisdiction and you consent to that transfer. Additionally, you understand that your Personal Information may be processed in countries where laws regarding processing Personal Information may be less stringent than in your country.
Governing Law and Dispute Resolution
This Privacy Policy, and all related matters are governed solely by the laws of Ontario, Canada and applicable federal laws of Canada, excluding any rules of private international law or the conflict of laws which would lead to the application of any other laws.
To the extent legally permitted, any claim or cause of action you may have arising from, connected with, or relating to this Privacy Policy or our handling of your Personal Information, or any related matters must be commenced within six (6) months, after the claim or cause of action arises, after which time the claim or cause of action is forever barred, regardless of any statute or law to the contrary.
How to Contact Us
If you have any questions or concerns about our privacy policy, please feel free to contact us at: inquiries@sooofinc.com or by mail to Sooof Inc., 70 University Avenue, Suite 1200, Toronto, ON, M5J 2M4, Attn: Legal Department.
Last updated: May 21, 2017.
