1. What Information We Collect About You
Personal Information you give us
You are free to explore the Website without providing any Personal Information about yourself. We request that you provide Personal Information about yourself when you submit web forms or interact with our Website, for example subscribing to an iwinBACK newsletter or requesting customer support.
"Personal Information" refers to any information that identifies you personally, including contact information, such as your name, e-mail address, company name, address, phone number, and other information about yourself or your business. Personal Information can also include information about you that is available on the internet, such as from Facebook, LinkedIn, Twitter and Google, or information that we acquire from service providers.
Personal Information includes Navigational Information or Payment Information where such information can directly or indirectly identify an individual.
We collect Navigational Information when you visit the Website. Navigational information refers to information about your computer and your visits to the Website such as your IP address, geographical location, browser type, referral source, length of visit and pages viewed. Please see the "Use of Navigation Information" section below.
Payment Information includes information we collect and process from you when you purchase iwinBACK products and services, including credit card numbers and billing information, using third party PCI-compliant service providers.
When you view content provided by us, we automatically collect information about your computer hardware and software. This information can include your IP address, browser type, domain names, internet service provider (ISP), the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, clickstream data, access times and referring website addresses. This information is used by iwinBACK to provide general statistics regarding use of the Website.
Information we collect from third parties
From time to time, we may receive Personal Information about you from third party sources such as social media websites.
2. How We Use Information We Collect
We Never Sell Personal Information
We will never sell your Personal Information to any third party.
Use of Personal Information
- improve your browsing experience by personalising the Website;
- develop and improve our products and services;
- promote use of our services to you and share promotional and information content with you in accordance with your communication preferences;
- provide other companies with statistical information about our users -- but this information will not be used to identify any individual user and will only be shared on an aggregate and de-identified basis;
- provide any information that you have requested;
- contact you about billing, account management and other administrative matters;
- investigate and help prevent security issues and abuse; or
- meet legal requirements.
Legal basis for processing Personal Information
Our legal basis for collecting and using the Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it. However, we will normally collect Personal Information from you only where we have your consent to do so, where we need the Personal Information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect Personal Information from you.
If we ask you to provide Personal Information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Information is mandatory or not (as well as of the possible consequences if you do not provide your Personal Information). Similarly, if we collect and use your Personal Information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.
Use of Navigational Information
We use Navigational Information to operate and improve the Websites and to provide you with a better experience when you interact with iwinBACK. We may also use Navigational Information alone or in combination with Personal Information to provide you with personalised information about iwinBACK. Navigational Information, such as IP address, is used to approximate your location. For example, we may use your approximate location to provide content that has been translated or send emails at certain times using your local time zone.
You may disable the collection and use of your location data through your browser, operating system, or device-level settings.
Customer Testimonials and Comments
We post customer testimonials and comments on our Website, which may contain Personal Information. We obtain each customer's consent via email prior to posting the customer's name and testimonial.
Use of Payment Information
Security of your Personal Information
We use a variety of security technologies and procedures to help protect your Personal Information from unauthorized access, use or disclosure. We secure the Personal Information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. All Personal Information is protected using appropriate physical, technical and organizational measures.
Retention of Personal Information
How long we keep information we collect about you depends on the type of information, as described in further detail below. After such time, we will either delete or anonymize your information or, if this is not possible, then we will securely store your information and isolate it from any further use until deletion is possible.
We retain Personal Information that you provide to us where we have an ongoing legitimate business need to do so (for example, as needed to comply with our legal obligations, resolve disputes and enforce our agreements).
When we have no ongoing legitimate business need to process your Personal Information, we securely delete the information or anonymise it or, if this is not possible, securely store your Personal Information and isolate it from any further processing until deletion is possible. We will delete this information at an earlier date if you so request, as described in the "How to Access & Control Your Personal Information" below.
If you have elected to receive marketing communications from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our content, products, or services, such as when you last opened an email from us or ceased using your IwinBACK account. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.
3. How we Share Information we Collect
We employ other third-party service providers to provide services on our behalf to visitors to our Website and our customers and users of the iwinBACK products and services and may need to share your information with them to provide information, products or services to you. We might also share data with third parties but only if the data has been de-identified in a way so it cannot be used to identify you. Examples may include removing repetitive information from prospect lists, analysing data or performing statistical analysis on interactions on our Website, providing marketing assistance, processing credit card payments, supplementing the information you provide us in order to provide you with better service, developing and improving the product and services, and providing customer service or support. These service providers are prohibited from using your Personal Information except for these purposes, and they are required to maintain the confidentiality of your information. In all cases where we share your information with such agents, we explicitly require the agent to acknowledge and adhere to our privacy and data protection policies and standards.
If we (or our assets) are acquired by another company, whether by merger, acquisition, bankruptcy or otherwise, that company would receive all information gathered by iwinBACK on visitors to the Website and our customers and users of the iwinBACK products and services. In this event, you will be notified via a prominent notice on our website of any change in ownership, uses of your Personal Information, and choices you may have regarding your Personal Information.
We reserve the right to use or disclose your Personal Information if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or comply with a law, court order, or legal process.
4. How We Transfer Data We Collect Internationally
International Transfers within iwinBACK’s Entities
To facilitate our global operations, we transfer information to and allow access to that information from countries in which the iwinBACK affiliated entities have operations for the purposes described in this policy.
International transfers to third parties
5. Cookies and Similar Technologies
The Website uses the following cookies:
Google Analytics, is a web analytics service provided by Google, Inc. (Google). Google Analytics uses "cookies", which are text files placed on your computer, to help the Website analyse how users use the site. The information generated by the cookie about your use of the Website (including your IP address) will be transmitted to and stored by Google.
Google will use this information to evaluate your use of the Website, compiling reports on the Website activity for iwinBACK and providing other services related to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf.
By using our Website you consent to the processing of data about you by Google in the manner and for the purposes set out above. To find out more, see “How Google uses data when you use our partners’ sites or apps”, (located at www.google.com/policies/privacy/partners/, or any other URL Google may provide from time to time.
Third Party Tracking Technologies
6. How to Access & Control Your Personal Information
Reviewing, Correcting and Removing Your Personal Information
You have the following data protection rights:
- You can request access, correction, updates or deletion of your Personal Information.
- You can object to processing of your Personal Information, ask us to restrict processing of your Personal Information or request portability of your Personal Information.
- If we have collected and process your Personal Information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.
- You have the right to complain to a data protection authority about our collection and use of your Personal Information. Contact details for data protection authorities in the EEA, Switzerland and certain non-European countries (including the US and Canada) are available at https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm
To exercise any of these rights, please write to us by email to firstname.lastname@example.org or by mail to iwinBACK Sales Inc., 100, 17619 – 96th Avenue Surrey, British Columbia, V4N 4A9, Canada, Attn: Privacy. We will respond to your request to change, correct, or delete your information within a reasonable timeframe and notify you of the action we have taken.
To Unsubscribe from Our Communications
You may unsubscribe from our marketing communications by clicking on the "unsubscribe" link located on the bottom of our e-mails, updating your communication preferences, or by contacting us by email to email@example.com or by mail to iwinBACK Sales Inc., 100, 17619 – 96th Avenue Surrey, British Columbia, V4N 4A9, Canada, Attn: Privacy.
Customers cannot opt out of receiving transactional emails related to their account with us or the Subscription Service.
7. Data Protection Officer