Privacy policy
Website, dashboard, and portal
Last Updated: February 13, 2024
THIS POLICY
This website Privacy Policy (this "Policy") is incorporated into and forms part of the OFFSTREET WEBSITE TERMS OF SERVICE AGREEMENT (the "Terms of Service") of this website (this "Website"), the portal (the “Portal”), and the dashboard (the “Dashboard”) (collectively, the “Services”). USE OF THIS WEBSITE CONSTITUTES YOUR EXPRESS AND UNCONDITIONAL ACCEPTANCE OF THE TERMS OF USE. PLEASE READ THE TERMS OF USE CAREFULLY. IF YOU DO NOT AGREE TO ANY OF THE TERMS OF USE, DO NOT ACCESS OR USE THE SERVICES.
OFFSTREET Technology Inc. (“OFFSTREET”) recognizes the importance of maintaining and protecting the privacy of personal information. This Policy relates only to the information OFFSTREET may collect through use of the Services and how such information may be used and disclosed by OFFSTREET.
OFFSTREET Technology Inc. (“OFFSTREET”) recognizes the importance of maintaining and protecting the privacy of personal information. This Policy relates only to the information OFFSTREET may collect through use of the Services and how such information may be used and disclosed by OFFSTREET.
TABLE OF CONTENTS
- APPLICABLE PRIVACY LEGISLATION
- DEFINITIONS
- PRINCIPLES RELATING TO THE PROCESSING OF PERSONAL DATA
- INDIVIDUAL PRIVACY RIGHTS
- SERVICES PRIVACY
- DATA
- LAWFULNESS OF DATA PROCESSING
- PRIVACY BY DESIGN
- CONTRACTS INVOLVING THE PROCESSING OF PERSONAL DATA
- INTERNATIONAL TRANSFERS OF PERSONAL DATA
- DATA PROTECTION OFFICER
- ACCOUNT INFORMATION
- AMENDMENTS
- CONTACT US
1. APPLICABLE PRIVACY LEGISLATION
The list below shows the main items of privacy legislation that apply to the countries (or groups of countries) and states within which OFFSTREET operates.
- [Canada] - [Personal Information Protection and Electronic Documents Act (PIPEDA)]
- [Canada – Quebec] - [Act respecting the protection of personal information in the private sector]
- [European Union] - [General Data Protection Regulation (GDPR)]
- [United Kingdom] - [UK GDPR Data Protection Act]
- [USA – California] - [California Consumer Privacy Act (CCPA)]
[Note: the above table shows examples of countries in which privacy legislation exists; there are many more, and a full understanding must be gained of the legislation that applies to the activities of your organization.]
OFFSTREET has a legal obligation to comply with the provisions of this legislation at all times. Whilst there will be variations in these provisions, this Policy establishes the key principles that are commonly required to be observed in such legislation.Significant fines may be applicable if a breach is deemed to have occurred under the relevant privacy legislation, which is designed to protect the personal data of citizens of the country (or state, region or countries) involved. It is OFFSTREET’s policy to ensure that our compliance with applicable legislation is clear and demonstrable at all times.
OFFSTREET has a legal obligation to comply with the provisions of this legislation at all times. Whilst there will be variations in these provisions, this Policy establishes the key principles that are commonly required to be observed in such legislation.Significant fines may be applicable if a breach is deemed to have occurred under the relevant privacy legislation, which is designed to protect the personal data of citizens of the country (or state, region or countries) involved. It is OFFSTREET’s policy to ensure that our compliance with applicable legislation is clear and demonstrable at all times.
2. DEFINITIONS
The definitions used within privacy legislation vary and it is not appropriate to reproduce them all here. However, the common terms used within this Policy are as follows:
- Personal data: Any information that (a) can be used to identify the personal data principal to whom such information relates, or (b) is or might be directly or indirectly linked to a personal data principal.
- Personal data principal: Natural person to whom the personal data relates. This term is also referred to as data subject.
- Processing of personal data: Operation or set of operations performed upon personal data. Examples of processing operations of personal data include, but are not limited to, the collection, storage, alteration, retrieval, consultation, disclosure, anonymization, pseudonymization, dissemination or otherwise making available, deletion or destruction of personal data.
- Data Controller: Privacy stakeholder (or privacy stakeholders) that determines the purposes and means for processing personal data other than natural persons who use data for personal purposes.
- Data Processor: Privacy stakeholder that processes personal data on behalf of and in accordance with the instructions of a data controller.
3. PRINCIPLES RELATING TO THE PROCESSING OF PERSONAL DATA
There are a number of fundamental principles upon which most privacy legislation is based. These are summarized as follows:
- Lawfulness, fairness and transparency - personal data shall be processed lawfully, fairly and in a transparent manner in relation to the personal data principal
- Purpose limitation – personal data shall be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes
- Data minimization – the personal data collected and stored shall be adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed
- Accuracy – personal data shall be accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that is inaccurate, having regard to the purposes for which it is processed, is erased or rectified without delay
- Storage limitation – personal data shall be kept in a form which permits identification of personal data principals for no longer than is necessary for the purposes for which the personal data is processed
- Integrity and confidentiality – personal data shall be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures
Processing of special categories of personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation shall be prohibited. Exception to this restriction is only applicable by lawful exceptions including but not limited to processing necessary to: reasons of public interest, purposes of preventive medicine, and defense or exercise of a legal claim.
OFFSTREET will ensure that it complies with all these principles both in the processing and as part of the introduction of new methods of processing such as new IT systems.
OFFSTREET will ensure that it complies with all these principles both in the processing and as part of the introduction of new methods of processing such as new IT systems.
4. INDIVIDUAL PRIVACY RIGHTS
The personal data principal also has rights with regard to their personal data. These will generally consist of:
- The right to be informed
- The right of access
- The right to rectification
- The right to erasure
- The right to restrict processing
- The right to data portability
- The right to object
- Rights in relation to automated decision making and profiling.
Each of these rights are supported by appropriate procedures within OFFSTREET that allow the required action to be taken within the timescales stated in the applicable privacy legislation.
These timescales are shown in the list below:
These timescales are shown in the list below:
- The right to be informed - When data is collected (if supplied by personal data principal) or within one month (if not supplied by personal data principal)
- The right of access - One month
- The right to rectification - One month
- The right to erasure - Without undue delay
- The right to restrict processing - Without undue delay
- The right to data portability - One month
- The right to object - On receipt of objection
- Rights in relation to automated decision making and profiling - Not specified
If OFFSTREET does not take action on the request of the personal data principal, OFFSTREET shall inform the personal data principal at the latest within one month of receipt of the request of the reasons for not taking action.
In cases where requests from a personal data principal are unfounded or excessive, OFFSTREET may either: charge a reasonable fee taking into account the administrative costs of providing the information/communication/taking the action requested; or refuse to act on the request.
Furthermore, OFFSTREET may request additional information necessary to confirm the identity of the personal data principal making the request. The information provided to personal data principals shall be comprehensible and in a clearly legible manner with an overview of the intended processing.
Moreover, OFFSTREET shall take reasonable steps to inform relevant data controllers, data processors, and recipients (as applicable) of request of rectification/erasure/restriction of processing from the data principal, unless this proves impossible or involves disproportionate effort.
In cases where requests from a personal data principal are unfounded or excessive, OFFSTREET may either: charge a reasonable fee taking into account the administrative costs of providing the information/communication/taking the action requested; or refuse to act on the request.
Furthermore, OFFSTREET may request additional information necessary to confirm the identity of the personal data principal making the request. The information provided to personal data principals shall be comprehensible and in a clearly legible manner with an overview of the intended processing.
Moreover, OFFSTREET shall take reasonable steps to inform relevant data controllers, data processors, and recipients (as applicable) of request of rectification/erasure/restriction of processing from the data principal, unless this proves impossible or involves disproportionate effort.
5. SERVICES PRIVACY
OFFSTREET does not collect personally identifiable information through the Services unless a user voluntarily sends such information email through a link on the Services, through signing up for an account as required to use the Services (an “Account”). Any communication with OFFSTREET is subject to the Terms of Use. OFFSTREET only uses personally identifiable information for the purposes of responding to any inquiries we receive from you. OFFSTREET will not disclose to anyone any personally identifiable information collected through the Services unless:
- we have your consent to do so (express or implied);
- we have a good faith belief that disclosure of the information is necessary to protect our rights or property; or
- we are required to do so by law.
OFFSTREET employs "cookies" on the Services. Cookies are small pieces of text downloaded to your computer or mobile device when you visit a website. Cookies track your visits to the Services and provide services such as remembering your preferences and settings, showing advertisements that are relevant to your interests, and personalizing your experience on the Services.
Some cookies known as “analytic cookies'' are used to gather information, but this information does not directly identify you. The information collected is anonymous, but allows us to see the overall patterns of usage. OFFSTREET may use such technical information for purposes such as improving the operation of the Services, improving the Content and for compiling statistical information about the use of and access to the Services. OFFSTREET will not attempt to associate any anonymous technical information collected with any personally-identifiable information unless:
Some cookies known as “analytic cookies'' are used to gather information, but this information does not directly identify you. The information collected is anonymous, but allows us to see the overall patterns of usage. OFFSTREET may use such technical information for purposes such as improving the operation of the Services, improving the Content and for compiling statistical information about the use of and access to the Services. OFFSTREET will not attempt to associate any anonymous technical information collected with any personally-identifiable information unless:
- we have your consent to do so (express or implied);
- we have detected, or reasonably suspect, an attempt to damage or breach the security of this Services; or
- we are required to do so by law.
6. DATA
The Services do not automatically gather personal information about you. The types of personal information we collect and share depend on your use of the Services and its functions. We generally collect the following types of information (collectively, the “Data”):
- Personal information – We may collect certain personal information including, but not limited to, your name, address, email address, telephone numbers, contact information and other similar information from which your identity is discernible. We will only collect personal information if you voluntarily supply it.
- Access and login information – We may record certain information regarding your access to the Website such as what areas you visit and what services you access. These logs may include information such as your personal data, your interaction with the service, internet protocol address, browser type, browser language, the date and time of your request and one or more cookies that may uniquely identify your browser or your account.
- Communications – Email or other communications you send to us may be retained in order to process your inquiries, respond to your requests and improve services to you.
- Third party applications or services – We may make available third party applications and services through the Services. The information collected by OFFSTREET when you access a third party application or service is processed under this Privacy Policy. However, any information collected by the third party application is governed by the privacy policy of such a third party.
- Links to other websites – The Services may contain links to other websites. This Privacy Policy applies to the Services only. We do not exercise any control over any third party sites linked or displayed on the Services. These other sites may place their own cookies or other files on your computer, collect data or solicit personal information from you. You should review the privacy policies of those third party websites so you can understand how they collect, use and share your information.
This Privacy Policy applies solely to Data we collect via the Services, and does not apply to information we collect in any other fashion. Please remember that if you post any of your personal information in public areas of the Services, such as in online forums or chat rooms, such information may be collected and used by others over whom OFFSTREET has no control. We are not responsible for the use made by third parties of information you post or otherwise make available in public areas of the Services.
We strive to protect your Data from unauthorized access, use, or disclosure using reasonable technical and organizational measures designed to secure your personal information from accidental loss and from unauthorized access, use, alternation or disclosure. However, the use of such measures is not, and should not be considered to be, any type of guarantee or warranty by us that your Data will not be accessed by third parties or that third parties will never be able to defeat those measures or use your personal information for improper purposes.
We collect and use your Data to:
We strive to protect your Data from unauthorized access, use, or disclosure using reasonable technical and organizational measures designed to secure your personal information from accidental loss and from unauthorized access, use, alternation or disclosure. However, the use of such measures is not, and should not be considered to be, any type of guarantee or warranty by us that your Data will not be accessed by third parties or that third parties will never be able to defeat those measures or use your personal information for improper purposes.
We collect and use your Data to:
- Provide products, services and information to you;
- Communicate with you regarding updates to the Services products, services, and information;
- Foster positive user experience;
- Operate and improve the Services products, services, and information;
- Inform you of other products, services or information available from OFFSTREET or its affiliated entities;
- Contact you about your opinion of existing or potential products, services or information provided via the Services;
- Respond to your feedback, queries or requests;
- Create products, services and information that may meet your needs;
- Better tailor and improve the features of offered products, services and information.
The Services may contain hypertext links to other third party websites which are not governed by this Policy. OFFSTREET is not responsible for the privacy practices or policies of third party websites or the owners or operators thereof.
OFFSTREET utilizes the Google Maps API(s) to enhance user experience on our platform. By using our service, you acknowledge and agree that we may collect and process information as described in the Google Privacy Policy. Please refer to the Google Privacy Policy for details on how Google collects, uses, and protects your information when you use Google Maps. OFFSTREET’s incorporation of the Google Privacy Policy by reference does not imply any endorsement, approval, or affiliation with Google.
OFFSTREET utilizes the Google Maps API(s) to enhance user experience on our platform. By using our service, you acknowledge and agree that we may collect and process information as described in the Google Privacy Policy. Please refer to the Google Privacy Policy for details on how Google collects, uses, and protects your information when you use Google Maps. OFFSTREET’s incorporation of the Google Privacy Policy by reference does not imply any endorsement, approval, or affiliation with Google.
7. LAWFULNESS OF DATA PROCESSING
Depending on the legislation involved, there may be a number of alternative ways in which the lawfulness of a specific case of processing of personal data may be established. It is OFFSTREET policy to identify the appropriate basis for processing and to document it, in accordance with the applicable legislation. The main options are described in brief in the following sections.
1. CONSENT
Where appropriate, OFFSTREET will obtain consent from a personal data principal to collect and process their data. In cases of children being below the age specified in applicable legislation, parental consent will be obtained. Transparent information about our usage of their personal data will be provided to personal data principals at the time that consent is obtained and their rights regarding their data explained, such as the right to withdraw consent. This information will be provided in an accessible form, written in clear language and free of charge.If the personal data is not obtained directly from the personal data principal, then this information will be provided to the personal data principal within a reasonable period after the data is obtained and definitely within one month.
2. PERFORMANCE OF A CONTRACT
Where the personal data collected and processed is required to fulfill a contract with the personal data principal, consent is not required. This will often be the case where the contract cannot be completed without the personal data in question, for example, a delivery cannot be made without an address.
3. LEGAL OBLIGATION
If the personal data is required to be collected and processed in order to comply with applicable law, then consent is not required. This may be the case for some data related to employment and taxation for example, and for many areas addressed by the public sector. For example, processing of personal data relating to criminal convictions and offenses or related security measures.
4. VITAL INTERESTS OF THE PERSONAL DATA PRINCIPAL
In a case where the personal data is required to protect the vital interests of the personal data principal or of another natural person, then this may be used as the lawful basis of the processing. OFFSTREET will retain reasonable, documented evidence that this is the case, whenever this reason is used as the lawful basis of the processing of personal data. As an example, this may be used in aspects of social care, particularly in the public sector.
5. TASK CARRIED OUT IN THE PUBLIC INTEREST
Where OFFSTREET needs to perform a task that it believes is in the public interest or as part of an official duty then the personal data principal’s consent will not be requested. The assessment of the public interest or official duty will be documented and made available as evidence where required.
6. LEGITIMATE INTERESTS
If the processing of specific personal data is in the legitimate interests of OFFSTREET and is judged not to affect the rights and freedoms of the personal data principal in a significant way, then this may be defined as the lawful reason for the processing. Again, the reasoning behind this view will be documented.
8. PRIVACY BY DESIGN
OFFSTREET has adopted the principle of privacy by design and will ensure that the definition and planning of all new or significantly changed systems that collect, or process personal data will be subject to due consideration of privacy issues, including the completion of one or more privacy impact assessments.
The privacy impact assessment will include:
The privacy impact assessment will include:
- Consideration of how as well as what types of personal data will be processed and for what purposes
- Assessment of whether the proposed processing of personal data is both necessary and proportionate to the purpose(s)
- Assessment of the risks to individuals in processing the personal data
- What controls are necessary to address the identified risks and demonstrate compliance with applicable legislation
Use of techniques such as data minimization/pseudonymisation/encryption will be considered where applicable and appropriate, including at the end of processing, and the mechanisms used to achieve them will be documented.
Where a data protection impact assessment indicates that the processing would result in a high risk in the absence of measures taken by the controller to mitigate the risk, OFFSTREET shall consult the supervisory authority prior to processing.
Where a data protection impact assessment indicates that the processing would result in a high risk in the absence of measures taken by the controller to mitigate the risk, OFFSTREET shall consult the supervisory authority prior to processing.
9. CONTRACTS INVOLVING THE PROCESSING OF PERSONAL DATA
OFFSTREET will ensure that all relationships it enters that involve the processing of personal data are subject to a documented contract that includes the specific information and terms required by the applicable legislation.
10. INTERNATIONAL TRANSFERS OF PERSONAL DATA
Transfers of personal data between countries will be carefully reviewed prior to the transfer taking place to ensure that they fall within the limits imposed by the applicable legislation. This depends partly on the relevant authority’s judgment (for example in the case of the GDPR, the European Commission) as to the adequacy of the safeguards for personal data applicable in the receiving country and this may change over time.
Where an adequacy decision (or similar statement) does not exist for a destination country, an appropriate safeguard such as standard contractual clauses will be used, or a relevant exception identified as permitted under the applicable legislation.
[Intra-group international data transfers will be subject to legally binding agreements referred to as Binding Corporate Rules (BCR) which provide enforceable rights for personal data principals.]
Where an adequacy decision (or similar statement) does not exist for a destination country, an appropriate safeguard such as standard contractual clauses will be used, or a relevant exception identified as permitted under the applicable legislation.
[Intra-group international data transfers will be subject to legally binding agreements referred to as Binding Corporate Rules (BCR) which provide enforceable rights for personal data principals.]
11. DATA PROTECTION OFFICER
A defined role of Data Protection Officer (DPO) is generally required under privacy legislation if an organization is a public authority, if it performs large scale monitoring or if it processes particularly sensitive types of data on a large scale. The DPO is required to have an appropriate level of knowledge and can either be an in-house resource or outsourced to an appropriate service provider.Based on these criteria, OFFSTREET does not require a Data Protection Officer to be appointed
12. ACCOUNT INFORMATION
OFFSTREET may send you newsletters, commercial e-mails or other communications that may be of interest to you from the Services or third parties. You may opt-out at any time by editing your Account as described above. Likewise, if you previously opted not to receive such communications, you may later opt-in by editing your Account.
You may review, delete, correct, update or change your information on the Services at any time by simply logging into your account.
You may also:
You may review, delete, correct, update or change your information on the Services at any time by simply logging into your account.
You may also:
- remove your Account and information from the Services; or
- elect to no longer receive services from us.
If you wish to remove your Account and/or personal information from the Services, or elect to no longer receive services from us, please contact us using the contact information provided below.
13. AMENDMENTS
OFFSTREET reserves the right to, at any time and from time to time, add to, change, update or modify this Policy by posting such change, update or modification on the Services. Your use of the Services after such amendments are posted by OFFSTREET signifies your acceptance of any revised terms of this Policy. You are responsible for periodically visiting this webpage to review the terms and conditions of this Policy. You may not change, modify or amend this Policy in any manner.
14. CONTACT US
If you have any questions about this Privacy Policy, please contact:
Offstreet Technology Inc.
2374 College Ave
Regina, Saskatchewan S4P0S8
Canada
support@joinoffstreet.com
Offstreet Technology Inc.
2374 College Ave
Regina, Saskatchewan S4P0S8
Canada
support@joinoffstreet.com
