Privacy statement - Canada
Last updated: February 28, 2024
About this statement
Complementing (however, do not substitute) the general Privacy Policy provided by Upclick Malta Limited dba Upclick (“Company” or “we” or “us”) and its affiliated companies.
Scope and applicability
This statement applies to Data Subjects residing in Canada and is designed to comply with the Personal Information Protection and Electronic Documents Act (“PIPEDA”), and with the Quebec Privacy Legislation Modernization Act, also known as Law 25 (“Law 25”).
Terms and definitions
Any terms defined in the Privacy Policy have the same meaning when used in this notice. Any terms we use in this Canadian notice that are not defined will have the meaning we provide in the Privacy Policy or other agreements.
Collection of Personal Information
As described in our Privacy Policy, the following data categories are collected about you:
- Identifiers (online and physical)
- Online and network activity
- Device information
- Usage information
- Payment and billing information
- Marketing and advertising information
- Customer support and customer relation information
For more details about the elements in each category, please refer back to our general Privacy Policy.
Use of Personal Information
We may use your personal information for one or more of the following purposes:
- To provide products and services to you
- To communicate with you about your orders and shipments
- To improve our products and services
- To personalize your experience on our website
- To send you marketing communications.
Retention and disposal of personal information
In our general privacy policy we explain the retention schedule of each personal data we collect. As a general rule, these are our data retention policies:
- We retain personal data for as long as is required to establish the purpose for which it was collected.
- We retain personal data beyond such a period of time when applicable legislation requires us to do so (for example, tax, labor, and so forth).
- We may retain personal data for a longer period of time when we want to develop and improve our products and services over time. Depending on the nature, type and scope of such data, we may employ pseudo-anonymization measures to safeguard longer retention periods of such data.
- Account and subscription information is retained until a valid and verified required for deletion is processed.
- Subject to exemptions, we delete personal data in the following circumstances:
- Valid and verifiable request to delete.
- No longer necessary to serve the purpose for which it was obtained or to comply with legal requirements.
- If we discover it was unlawfully processed (for example, minors, or if a valid consent was not obtained).
Third parties and data transfers
As part of Upclick's global operations, we share data with third parties, as described in our general privacy policy. This includes parties residing outside of Quebec and/or Canada. The following are categories of third parties with whom we share personal data. You have the right to request to know the name of a specific third party or the names under each category.
- Upclick affiliated companies (such as subsidiaries and parent companies)
- Hosting services and storage vendors (such as Microsoft, Google and Amazon Web Services)
- Analytics, business intelligence and statistics vendors (such as Google Analytics)
- Support and customer services (such as ZenDesk)
- Compliance vendors (such as OneTrust)
- Customer relations management and mailing list (Such as SendGrid)
- Billing and payment solutions (such as Moneris, Nuvei, Credorax, Adyen, PayPal)
- Technology partners that are integrated into Products or Websites (such as Acutrack, CyberSource, Kount and other features)
- Special cases (fraud prevention or investigation)
For more details about third-party data disclosures, please refer back to our general Privacy Policy or contact our DPO at dpo@upclick.com.
Your rights
Subject to certain exemptions provided by law, you may request to exercise one or more of the following rights.
- Right to be informed
- Right to access
- Right to rectification
- Right to erasure
- Right to withdraw consent
- Right to restrict processing
- Right to data portability
We will try to respond to all legitimate requests within 30 days. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you.
If you have a complaint about how we use your Personal Information, we would always prefer you to contact us first at dpo@upclick.com. You also have the right to make a complaint to the Privacy Commissioner of Canada (OPC), or, to the Quebec’s Commission d'accès à l'information (CAI), as applicable.
Security Measures
We take reasonable measures to protect your personal information from unauthorized access, use, disclosure, or destruction. We only share your personal information with third parties necessary to provide our products and services, and we require these third parties to adhere to the same privacy standards as we do.
Roles and responsibilities
- For questions regarding data privacy and data governance, please contact our Data Protection Officer (DPO) at: dpo@upclick.com.
- For questions about data security, please contact our DPO at the email above or our data security manager at: compliance@upclick.com.
Further information
If you have any questions about the Privacy Policy or have any concerns in terms of this Privacy Policy or the Company’s compliance with this Privacy Policy, please contact our privacy officer at the following address:
Upclick Malta Limited dba Upclick Ltd.
UPCLICK INC
7075 Place Robert-Joncas, Suite 142, Montreal, QC, Canada,
H4M 2Z2
UC Distribution LLC
2915 Ogletown Rd. #3783, Newark, DE 19713
UPCLICK MALTA LIMITED
48/4 Amery Street, Sliema SLM 1701
dpo@upclick.com