Privacy Policy


1.1 Our Commitment to Privacy 

Provision Software Corporation and its representatives and affiliates (collectively, “Provision”,  “we”, “us” or “our”) are committed to protecting your privacy. This Privacy Policy (as updated  from time to time, this “Privacy Policy”) has been designed to comply with Canada’s Personal  Information Protection and Electronic Documents Act and other applicable federal, state and  provincial privacy laws relating to the protection of personal information (collectively, “Privacy  

Laws”). This Privacy Policy forms part of and is hereby expressly incorporated into our Terms of  Service (the “Agreement”). 

1.2 Scope 

In this Privacy Policy, we explain how we collect, use, disclose and protect the personal  information of our Users (as defined below).  

You are a “User” if you are an individual and you access our website located at or and related webpages (collectively,  the “Site”), install or use any other software supplied by us, access any information, function,  feature, application, product or service made available by us or register an account with us  (collectively, the “Service”). 

Your “personal information” means any information about you as defined in applicable Privacy  Laws and includes information such as your full name, address, postal code, email address and  geographic location. It may also include information on how you use the Service. It does not  include business contact information or certain publicly available information. 

1.3 Updates 

We may modify this Privacy Policy at any time for any reason, effective upon posting an  updated version through the Service. If the modifications are significant, we will use  commercially reasonable efforts to provide you with prior notice via email or other reasonable  means. You should regularly review this Privacy Policy, as your continued use of the Service  after the date on which an updated version becomes effective constitutes your acceptance of  the updated Privacy Policy. In the event that you do not accept the updated Privacy Policy, your  sole and exclusive remedy is to cease your access and use of the Service. 


We may collect personal information when you provide it to us, including by way of your  interaction with us and your access and use of our Service. We try to minimize the collection of  personal information to only what is reasonable and necessary to provide our Service and to develop, assess and improve our Service. We only collect personal information if non-identifying  information is not sufficient for this purpose.  

We may collect the following categories of personal information about you: 

identifiers, which may include your name, address, email address, telephone number,  user ID, username or screen name, password, IP address or MAC address; • commercial information, which may include payment, banking or other financial  information; 

internet or network activity, which may include your operating system type and  version, web server type and version, PHP version, database type and version, cookie  information, device information, browsing information, browsing activities, platform use  data, mobile use data, referring domain, destination domain, destination path,  performance, security, software configuration, website user statistics, viewing activity  and communication preferences; 

mobile device information, which may include your mobile phone number, mobile  country code, unique device identifier, mobile advertising identifier (assigned by your  mobile platform), information about your mobile device screen size, date and time of  mobile device use and other mobile device-related information; 

geolocation information, which may include geographical information derived from  your IP address, MAC address or device GPS; 

audio, visual or electronic information, which may include screen sharing views or  any data contained in files uploaded, emailed or otherwise provided by you; • information from third parties (where you have authorized it); and 

other information, which may include the contents of your communications with us,  whether through email, social media, telephone or otherwise, and inferences we may  make from other personal information we collect. 


3.1 Purposes of Use and Disclosure 

We may use or disclose the personal information we collect about you for the following  purposes: 

• to verify your identity; 

• to contact you or your designated representatives; 

• to manage the administration of your account; 

• to provide you with our Service; 

• to maintain and improve our Service; 

• to develop new services; 

• to advertise, market and promote our Service; 

• to identify new users or customers; 

• to measure our performance; 

• to tailor the content and advertising on our Site and other services; 

• to manage your preferences; 

• to provide a more personalized user experience; 

• to monitor your compliance with any of your agreements with us;

• to satisfy our legal, regulatory and tax reporting requirements; 

• to establish our legal rights or defend against legal claims; 

• to protect you, us and others from fraud and error and to safeguard our business  interests; 

• to collect debts owed to us; 

• to manage or transfer our assets or liabilities, which may include in the event of an  acquisition, disposition, merger, amalgamation or other business transition or  transaction; and 

• for any other purpose which we disclose to you from time to time. 

If we ever wish to use or disclose the personal information we collect about you for a purpose  not previously identified, the new purpose will disclosed to you prior to such use or disclosure  and your consent to such use or disclosure will be sought (unless such use or disclosure is  required or authorized by law). 

3.2 Third Party Use and Disclosure 

To the extent permitted by applicable law, we may disclose the personal information we collect  about you to the following third parties: 

• our affiliates, agents or business partners; 

• our service providers, which may include service providers of website hosting, payment  processing, product delivery, accounting, legal, tax, consulting, professional advising,  surveys, market research, data analysis, reporting, and marketing services; 

• a purchaser, investor, new affiliate or other successor in the event that we or any  affiliate, portion, group or business unit of ours undergoes an acquisition, disposition,  merger, amalgamation or other business transition or transaction; 

• legal, governmental, regulatory, tax or judicial authorities (“Authorities”) to comply with  any law, directive, judicial or administrative order, legal process, investigation, warrant,  subpoena, government request, regulatory request or as otherwise required or  authorized by law or such Authorities; and 

• other third parties, including (a) to whom you have authorized us to disclose your  personal information, (b) to investigate, prevent or take action regarding suspected  illegal activities, fraud or violations of the Agreement, (c) to protect the safety or the  security of persons or property, and (d) to the extent we believe is reasonable and  necessary for the purposes set out in this Privacy Policy. 

Whenever we disclose personal information to third parties, we try to minimize the disclosure of  personal information to only what is reasonable and necessary for the third party to fulfill the  particular purpose for disclosure. We also require, by contractual means, that the third party  maintain and protect the confidentiality of the disclosed personal information to the same degree  as it if were in our possession. 

At times, we may transfer your personal information outside of Canada, including to third parties  outside of Canada who may perform services for us which involve some of the personal  information we collect about you. Accordingly, some of your information may be processed or  stored in the jurisdiction where the third party is located. This information is subject to both the  laws of Canada and the laws of the third party's jurisdiction and may be accessible by the  Authorities of other jurisdictions. When we transfer personal information to third parties, we ensure by contractual means that the transferred personal information is protected to the same  degree as if it were in our possession. 


4.1 Obtaining Consent 

We will not collect, use or disclose your personal information without first obtaining your consent  (except where required or authorized by law). Your consent can be express, implied or given  through an authorized representative, such as a lawyer, agent or broker. 

By accessing or using our Site or Service or voluntarily providing your personal information to  us, you are consenting to the collection, use and disclosure of your personal information in  accordance with this Privacy Policy 

4.2 Withdrawing Consent 

You may withdraw all or part of your consent for us to collect, use or disclose your personal  information in accordance with this Privacy Policy at any time upon reasonable notice to us in  writing, subject to legal, contractual or other restrictions. The withdrawal of your consent may  affect our ability to provide you with the same access to or use of our Service. 

You may also withdraw all or part of your consent to receive promotional emails from us by  following the opt out instructions provided in such emails. If you opt-out, we may still send you  non-promotional emails, such as messages about your account or our ongoing business  relations. 


5.1 Accuracy 

We try to ensure that the personal information we collect about you is accurate, complete and  up to date. In some cases, we rely on you to ensure that certain personal information, such as  your address or telephone number, is accurate, complete and up to date. Users are requested to notify us as soon as possible of any changes, deletions or corrections to their personal  information so that we may keep such information up to date.  

5.2 Accessibility 

With certain limited exceptions as provided under applicable Privacy Laws, you have the right to  access your personal information held by us and to request that the information be corrected if it  is inaccurate, incomplete or collected in violation of law. You may update or correct information  about yourself by contacting us in accordance with Section 7. Please note that we may be  unable to provide you with full access to your personal information if we are prohibited by law or  regulatory reasons to do so, or if the information has been securely destroyed in accordance  with our practices. Subject to legal or contractual restrictions, we will provide you with an  explanation if we are unable to fulfill your access request. In accordance with applicable law, we must take steps to verify your identity before fulfilling any of the above requests. If you maintain  an account with us, we may verify your identity through existing authentication practices for the  account, such as your username and password. We may also verify your identity by matching  two or three data points of identifying information about you. 

5.3 Safeguards 

We maintain physical, electronic and procedural controls consistent with regulatory standards to protect the personal information in our custody or control. Reasonable measures, such as  system access security controls, safeguards to detect and prevent security system failures,  restricted access, and employee training, have been implemented to help protect personal  information from unauthorized access, collection, use, disclosure, copying, modification,  disposal or similar risks. We also take reasonable steps, through contractual or other  reasonable means, to ensure that a comparable level of personal information protection is  implemented by the third parties who assist us in providing products and services to you.  However, please note that complete and permanent confidentiality and security cannot be  guaranteed when information is transmitted electronically. 

You can also play an important role in protecting your personal information. For example, you  should: 

• create a strong and unique password for your user accounts; 

• never share your user accounts or passwords with anyone (note that we will never ask  you for your password, including in any unsolicited communication such as letters,  telephone calls or emails); 

• log out of your user account each time you are finished using it, especially if you share  your device with others; 

• use a strong and unique password on your device; and 

• never post information on our Site that you do not want to be viewed or used by others. 5.4 Retention and Disposal 

We retain personal information in accordance with our records retention program. Such  personal information is retained for as long as is necessary for the purposes set out in this  Privacy Policy, unless a longer period is permitted or required under applicable law or is needed  to resolve disputes or protect our legal rights. After this period, such personal information will be  destroyed or disposed of in a manner commensurate with its sensitivity. 


6.1 Cookies and Similar Technologies 

We may use cookies and similar technologies to measure web activity to provide you with a  better user experience on our Site and during the course of providing our Services. A "cookie" is  a unique numeric code that we transfer to your device so that we can keep track of your  interests and preferences and recognize you as a returning visitor to the Site and Service. If you  choose not to accept cookies from us, you will still be able to access many of the features on  our Site and Service, but with certain limitations to access and functionality.

6.2 Aggregated and Anonymized Personal Information 

To the extent permitted by applicable law, we may uses, process, transfer and store data about  Users or partners in an anonymous or pseudonymous manner. We may also aggregate  statistics that we gather about our Users, sales, usage data and products and services. We may combine such anonymized and/or aggregated personal information with other information  collected, including from third parties. With your consent or as permitted by applicable law, we  may use such anonymized and/or aggregated personal information in ways and for purposes  not previously identified in this Privacy Policy, including for benchmarking, analytics, research,  reporting, machine learning and other business purposes. 

6.3 Children 

Our Service is not targeted or directed at children under the age of 13, and we do not intend to,  or knowingly, collect or solicit personal information from children under the age of 13. If you  have reason to believe that a child under the age of 13 has provided personal information to us,  we encourage the child’s parent or guardian to contact us in accordance with Section 7 to  request that we remove the information from our systems. If we learn that any personal  information we collected has been provided by a child under the age of 13, we will promptly  delete that personal information. 

6.4 External Websites 

Our Service may provide URL links to other websites, mobile applications, resources or Internet  locations which we do not have control over (“External Websites”). Such links do not constitute  an endorsement by us of those External Websites. We have no control over and are not  responsible for External Websites, their content or any goods or services offered or made  available on them. Your access to or use of any External Website is subject to the terms of use  and privacy policy of that such External Website. 

6.5 Disclaimer to Complete Security 

By accepting this Privacy Policy, you acknowledge and agree that no data transmission over the  Internet is completely secure. We cannot guarantee or warrant the security of any information  you provide to us and you transmit such information to us at your own risk. 


7.1 Contact Us 

If you have questions or complaints with respect to our privacy policies and practices or if you  wish to request access to, or correction of, your personal information under our care and  control, please contact our Privacy Officer at: 

Attention: Provision Software Corporation 

Mailing Address: 155 Wellington Street West, 40th Floor 

Toronto, Ontario  

M5V 3J7 Canada


Inquiries or complaints will be dealt with promptly. We will acknowledge your query, investigate  it and provide you with a response within 30 days. 

7.2 File a Complaint 

If you believe the Privacy Laws relating to the protection of your personal information or this  Privacy Policy have not been respected, you may file a complaint with us. We will acknowledge  your complaint, investigate it and provide you with a response within 30 days. If, after an  investigation, your complaint is deemed justified, we will take appropriate steps to correct the  situation, including, if necessary, amending our policies and practices. If you are not satisfied  with the results of the investigation or the corrective measures taken by us, you may exercise  the remedies available to you under law by contacting the Office of the Privacy Commissioner of  Canada at the address below: 

Address: Office of the Privacy  

Commissioner of Canada 

30 Victoria Street 

Gatineau, QC K1A 1H3

Last Updated: September 28, 2022