Masterly Privacy Policy

Last modified: August 1, 2024

Currency Date: August 2, 2024

Introduction

Masterly Inc. and our affiliates ("Company" or "We") respect your privacy and are committed to protecting it by complying with this policy.

This policy describes:

  • How we collect, use, disclose, and protect the personal information of our customers and website users ("you").
  • Describes the types of information we may collect from you or that you may provide when you visit the website at https://www.masterly.ca (the "Masterly Website") and its applications and services including, but not limited to, the FindWare Application (the "FindWare App"), the MasterlySOS Application (the "MasterlySOS App"), and the Masterly Forms Application (the "Masterly Forms App") (collectively, the "Masterly Apps").
  • Our practices for collecting, using, maintaining, protecting, and disclosing that information.

We will only use your personal information in accordance with this policy unless otherwise required by applicable law. We take steps to ensure that the personal information that we collect about you is adequate, relevant, not excessive, and used for limited purposes.

Privacy laws in Canada generally define "personal information" as any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person. Personal information does not include business contact information, including your name, title, or business contact information.

This policy applies to information we collect, use, or disclose about you:

  • On the Masterly Website or the Masterly Apps.
  • In email, text, and other electronic messages between you and the Masterly Website or the Masterly Apps.
  • Through the Masterly Apps and desktop applications you download from the Masterly Website, which provide dedicated non-browser-based interaction between you and the Masterly Website.
  • When you interact with our advertising and applications on third-party websites and services if those applications or advertising include links to this policy.
  • Through offline interactions, such as in-person events, surveys, and forms.

The Masterly Website or the Masterly Apps may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. If you follow a link to a third-party website or engage a third-party plugin, please note that these third parties have their own privacy policies and we do not accept any responsibility or liability for these policies. We do not control these third-party websites, and we encourage you to read the privacy policy of every website you visit.

This policy DOES NOT apply to information that:

  • We collect through any other means, including on any other Company or third-party website (including our affiliates).
  • You provide to or is collected by any third party (including our affiliates), through any application or content (including advertising) that may link to or be accessible from or on the Masterly Website or the Masterly Apps.

Please read this policy carefully to understand our policies and practices for collecting, processing, and storing your information. If you do not agree with our policies and practices, your choice is not to use the Masterly Website or the Masterly Apps. By accessing or using the Masterly Website or the Masterly Apps, you indicate that you understand, accept, and consent to the practices described in this policy.

This policy may change from time to time. Your continued use of the Masterly Website or the Masterly Apps after we make changes indicates that you accept and consent to those changes, so please check the policy periodically for updates. We will notify you in advance of any material changes to this policy and obtain your consent to any new ways that we collect, use, and disclose your personal information.

Functionality of the Masterly Apps

The FindWare App is designed to assist you in managing your assets tagged with a FindWare Quick Response (QR) code or Near-Field Communication (NFC) tag and to communicate with individuals who have found your assets in the event that they are lost.

The MasterlySOS App is designed to connect you with your emergency contacts by allowing individuals who have encountered you in an emergency situation to scan a MasterlySOS QR code or NFC tag.

The Masterly Forms App is designed to create, distribute, complete, and process various types of forms, including text, numbers, dates, file uploads/downloads, and provide data verification via document uploads or API access to verified databases.

The functionalities of the FindWare App, the MasterlySOS App, and the Masterly Forms App are collectively referred to as the "Services".

Information We Collect About You

We collect and use several types of information from and about you, including:

  • Personal information that we can reasonably use to directly or indirectly identify you, such as your name, mailing address, e-mail address, telephone number, Internet protocol (IP) address used to connect your computer to the Internet, username or other similar identifier, account information, and any other identifier we may use to contact you ("personal information").
  • Personal information in addition to that listed above, including your date of birth, to be stored securely on the Masterly server in order for the Masterly Forms App to accurately complete a variety of third-party forms when directed by you.
  • Business-related information, namely information that relates to your business duties, including:
    • Title;
    • Duties;
    • Business address;
    • Business email address; and
    • Business telephone number.
  • Technical information, including your login information, browser type and version, app version, time zone setting, browser plug-in types and versions, operating system and platform, or information about your internet connection, the equipment you use to access the Masterly Website or the Masterly Apps, and usage details.
  • Non-personal details about your Website or App interactions, including any data changes in the profile section, the full Uniform Resource Locators (URLs), clickstream to, through and from the Masterly Website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, any data changes in the profile section, verification or validation time stamps, system logs, or any phone number used to call our customer service number.

How We Collect Information About You

We use different methods to collect your information, including through:

  • Direct interactions with you when you provide it to us, for example, by filling in forms or corresponding with us by phone, email, or otherwise.
  • Automated technologies or interactions, as you navigate through the Masterly Website or the Masterly Apps. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
  • Third party CRM software, such as ZenDesk, to communicate with end-users through tickets, the chatbot, or forms available on the Masterly Website or the Masterly Apps.

Information You Provide to Us

The information we collect directly from you on or through the Masterly Website or the Masterly Apps may include:

  • Information that you provide by filling in forms on the Masterly Website or the Masterly Apps. This includes information provided at the time of registering to use the Masterly Website, subscribing to our services, posting material, reporting errors that you encounter, changes to your profile information, or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with the Masterly Website or the Masterly Apps.
  • Emergency contact information, such as the name and telephone number of the third parties you designate in the MasterlySOS App as the parties to be contacted in the event of an emergency, provided you have received their consent to be designated as such and for their contact information to be collected by us.
  • Records and copies of your correspondence, including email addresses, if you contact us.
  • Your responses to surveys that we might ask you to complete for research purposes.
  • Details of transactions you carry out through the Masterly Website or the Masterly Apps, particularly the specific products purchased, and the fulfillment of your orders. You will be required to provide financial information through the third-party payment processing platform known as Stripe, Inc. before placing an order through the Masterly Website or the Masterly Apps.
  • Your search queries on the Website.

You may also provide information to be published or displayed (hereinafter, "posted") on public areas of the Masterly Website or the Masterly Apps or transmitted to other users of the Masterly Website or the Masterly Apps or third parties (collectively, "User Contributions"). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect. Additionally, we cannot control the actions of other users of the Masterly Website or the Masterly Apps with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that unauthorized persons will not view your User Contributions.

Additionally, you may also provide information to be transmitted to other users of the Masterly Apps or third parties, such as when you are communicating about your lost item or an emergency (collectively, "User Submissions"). Your User Submissions are transmitted to others at your own risk. Although we limit access to certain pages and do not share your personal information nor your emergency contacts’ information with other users of the Masterly Apps or third parties, please be aware that no security measures are perfect. Additionally, we cannot control the actions of other users of the Masterly Apps or third parties with whom you may choose to share your User Submissions. Therefore, we cannot and do not guarantee that unauthorized persons will not view your User Submissions.

Information We Collect Through Cookies and Other Automatic Data Collection Technologies

As you navigate through and interact with the Masterly Website and the Masterly Apps, we may use cookies or other automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  • Details of your visits to the Masterly Website or the Masterly Apps, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Masterly Website or the Masterly Apps.
  • Information about your computer and internet connection, including your IP address, operating system, and browser type.
  • Information about your mobile device and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically is statistical information and may include personal information, and we may maintain it or associate it with personal information we collect in other ways, that you provide to us, or receive from third parties. It helps us to improve the Masterly Website and to deliver a better and more personalized service, including by enabling us to:

  • Estimate our audience size and usage patterns.
  • Store information about your preferences, allowing us to customize the Masterly Website according to your individual interests.
  • Recognize you when you return to the Masterly Website.

The technologies we use for this automatic data collection may include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer or mobile device. You may refuse to accept browser cookies by activating the appropriate setting on your browser or device settings. However, if you select this setting, you may be unable to access certain parts of the Masterly Website or the Masterly Apps. Unless you have adjusted your browser settings so that it will refuse cookies, our system will issue cookies when you direct your device or browser to the Masterly Website or the Masterly Apps.
  • Flash Cookies. Certain features of the Masterly Website and the Masterly Apps may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on the Masterly Website or the Masterly Apps. Flash cookies are not managed by the same browser settings that are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
  • Web Beacons. Pages of the Masterly Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Third Party Use of Cookies and Other Tracking Technologies

Some content or applications on the Masterly Website or the Masterly Apps are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use the Masterly Website or the Masterly Apps. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioural) advertising or other targeted content. In addition to helping advertisers reach the right people for their products and services, behavioural advertising helps support the Masterly Website and the Masterly Apps so that you can enjoy free content.

You can opt-out of several third-party ad servers' and networks cookies simultaneously by using an opt-out tool created by the Digital Advertising Alliance of Canada and an opt-out tool created by the Network Advertising Initiative. You can also access these websites to learn more about online behavioural advertising and how to stop websites from placing cookies on your device. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.

We do not control these third parties' tracking technologies or how they are used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For more information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

  • To present the Masterly Website and the Masterly Apps and their contents to you.
  • To provide you with information, products, or services that you request from us.
  • To fulfill the purposes for which you provided the information or that were described when it was collected, or any other purpose for which you provide it.
  • To provide you with notices about your account/subscription, including expiration and renewal notices.
  • To carry out our obligations and enforce our rights arising from any contracts with you, including for billing and collection or to comply with legal requirements.
  • To notify you about changes to the Masterly Website or the Masterly Apps or any products or services we offer or provide through them.
  • To improve the Masterly Website or the Masterly Apps, products or services, marketing, or customer relationships and experiences.
  • To allow you to participate in interactive features, social media, or similar features on the Masterly Website or the Masterly Apps.
  • In any other way we may describe when you provide the information.
  • For any other purpose with your consent.

We may also use your information to contact you about our own and third parties' goods and services that may be of interest to you, as permitted by law. If you do not want us to use your information in this way, please e-mail us at support@masterly.ca. For more information, see Choices About How We Use and Disclose Your Information.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

  • To our affiliates.
  • In accordance with applicable law, to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Masterly Inc.'s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Masterly Inc. about our customers and users is among the assets transferred.
  • To third parties to market their products or services to you if you have consented to/not opted out of these disclosures. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them. For more information, see Choices About How We Use and Disclose Your Information.
  • To contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Website and App improvements and optimization, as well as the payment processing platform known as Stripe, Inc. that assists us with processing orders on the Masterly Website and the Masterly Apps) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy.
  • To fulfill the purpose for which you provide it. For example, if you give us an email address to use the "email a friend" feature of the Masterly Website or the Masterly App, we will transmit the contents of that email and your email address to the recipients. Or, when you provide your personal information on your Masterly account to be used to fill out third-party forms using the Masterly Forms App, we will use that personal information to fill out any third-party forms as directed by you.
  • For any other purpose disclosed by us when you provide the information.
  • With your consent.

We may also disclose your personal information:

  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law.
  • To enforce or apply our Terms and Conditions of Use, found at https://forms.masterly.ca/terms-and-conditions, and other agreements, including for billing and collection purposes.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Masterly Inc., our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Transferring Your Personal Information

Although we process and store your personal information in our facilities and servers in Canada, we may transfer personal information that we collect or that you provide as described in this policy to contractors, service providers, and other third parties we use to support our business and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy.

The third parties we use to support our business may process, store, and transfer your personal information in and to a foreign country, with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information through the laws of the foreign country. Whenever we engage a service provider, we require that its privacy and security standards adhere to this policy and applicable Canadian privacy legislation. We will also only transfer personal information pursuant to a legally valid transfer mechanism.

Our legal bases for transferring your personal information include:

  • Providing and maintaining our services through the contractors, service providers, and other third parties we use to support our business, such as analytics and search engine providers that assist us with Website and App improvement and optimization, as well as the payment processing platform known as Stripe, Inc. that assists us with processing orders on the Masterly Website and the Masterly Apps.
  • Our legitimate interests in protecting our services from abuse, fraud, or security risks, or in developing, improving, or promoting our services.
  • Your consent when we ask for your consent to process your personal information for a specific purpose that we communicate to you. You have the right to withdraw your consent at any time.
  • Compliance with our legal obligations when we use your personal information to comply with applicable law or when we protect our affiliates’, users’, or third parties’ rights, safety, and property.

You are welcome to contact us to obtain further information about Company policies regarding service providers outside of Canada. See Contact Information and Challenging Compliance.

By submitting your personal information or engaging with the Masterly Website or the Masterly Apps, you consent to this transfer, storage, or processing.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

  • Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website. If you disable or refuse cookies, please note that some parts of this Website may not be accessible or may not function properly. For more information about tracking technologies, see Information We Collect Through Cookies and Other Automatic Data Collection Technologies.
  • Promotional Offers from the Company. If you have opted in to receive certain emails from us but no longer wish to have your email address/contact information used by the Company to promote our own or third parties' products or services, you can opt-out by sending us an email stating your request to support@masterly.ca. If we have sent you a promotional email, you may unsubscribe by clicking the unsubscribe link we have included in the email. This opt-out does not apply to information provided to the Company as part of a product purchase, warranty registration, product service experience, or other transactions.
  • We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of several third-party ad servers' and networks' cookies simultaneously by using an opt-out tool created by the Digital Advertising Alliance of Canada or an opt-out tool created by the Network Advertising Initiative. You can also access these websites to learn more about online behavioural advertising and how to stop websites from placing cookies on your device. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.

Data Security

The security of your personal information is very important to us. We use physical, electronic, and administrative measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. We store all information you provide to us on secure servers of Amazon Web Services with appropriate configurations. Any payment transactions and billing information will be collected and handled by the third-party payment processing platform known as Stripe, Inc. We do not store your credit card or payment information. We only store a record of what was purchased in order to provide that service to you.

The safety and security of your information also depend on you. Where we have given you or where you have chosen a password for access to certain parts of the Masterly Website or the Masterly Apps, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Masterly Website or the Masterly Apps like message boards, which any Masterly Website visitor can view. Once you have registered an account with Masterly, certain login features, including a passwordless login and two-factor authentication, are available to you. These login features may only be used as an option to login to your account if activated by you under the security tab within your profile.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, as described in the preceding paragraphs, we cannot guarantee the security of your personal information transmitted to the Masterly Website or the Masterly Apps. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Masterly Website or the Masterly Apps.

Data Retention

Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances, we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.

Children Under the Age of 13

Our Website is not intended for children under 13 years of age. No one under age 13 may provide any personal information to or on the Masterly Website or the Masterly Apps. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on the Masterly Website or the Masterly Apps or on or through any of its features/register on the Masterly Website or the Masterly Apps, make any purchases through the Masterly Website or the Masterly Apps, use any of the interactive or public comment features of the Masterly Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at support@masterly.ca.

Accessing and Correcting Your Personal Information

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes. By law, you have the right to request access to and to correct the personal information that we hold about you.

You can review and change your personal information by logging into the Masterly Website or the Masterly Apps and visiting your account profile page.

If you want to review, verify, correct, or withdraw consent to the use of your personal information, you may also send us an email at support@masterly.ca to request access to, correct, or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. We may charge you a fee to access your personal information; however, we will notify you of any fee in advance.

We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

We will provide access to your personal information, subject to exceptions set out in applicable privacy legislation. Examples of such exceptions include:

  • Information protected by solicitor-client privilege.
  • Information that is part of a formal dispute resolution process.
  • Information that is about another individual that would reveal their personal information or confidential commercial information.
  • Information that is prohibitively expensive to provide.

If you are concerned about our response or would like to correct the information provided, you may contact our Privacy Officer at legal@masterly.ca.

If you delete your User Contributions or Submissions from the Masterly Website or the Masterly Apps, copies of your User Contributions or Submissions may remain viewable in cached and archived pages or might have been copied or stored by other Masterly Website users. Proper access and use of information provided on the Masterly Website or the Masterly Apps, including User Contributions and Submissions, is governed by our Terms and Conditions of Use, found at https://forms.masterly.ca/terms-and-conditions.

Withdrawing Your Consent

Where you have provided your consent to the collection, use, and transfer of your personal information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us at support@masterly.ca. Please note that if you withdraw your consent, we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the Masterly Website and the Masterly Apps’ home page. If we make material changes to how we treat our users' personal information, we will notify you through a notice on the Masterly Website and the Masterly Apps’ home page requiring active consent that you have read through the changes.

We include the date the privacy policy was last revised at the top of the page. You are responsible for periodically visiting the Masterly Website and the Masterly Apps and this privacy policy to check for any changes.

Contact Information and Challenging Compliance

We welcome your questions, comments, and requests regarding this privacy policy and our privacy practices. Please contact us at:

Privacy Officer
legal@masterly.ca
120 Adelaide Street West, Suite 2500
Toronto, Ontario, Canada
M5H 1T1

We have procedures in place to receive and respond to complaints or inquiries about our handling of personal information, our compliance with this policy, and with applicable privacy laws. To discuss our compliance with this policy, please contact our Privacy Officer using the contact information listed above.

Date: 2024 Aug 2

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