3. COLLECTION AND USE OF PERSONAL INFORMATION
3.1 Client Information. When you register for the Services or inquire about engaging IcebergIQ, IcebergIQ collects certain Personal Information from you (collectively, “Client Information”). In particular, IcebergIQ may collect your name, company name, email address, phone number, business address and/or billing information, such as credit card number and billing address.
IcebergIQ uses the Client Information to provide and deliver the Services you request, to communicate with you about services, and events, to provide thought leadership content, newsletters, and provide other news or information about us, for billing, and for other purposes which we will notify you about and seek your consent.
3.2 Client Customers. IcebergIQ conducts interviews with buyers and customers on behalf of our Clients. and provides this research to our Clients as part of the Services. In doing so, we may collect Personal Information about our Clients’ Customers from our Clients or their Customers directly, including first and last name, role within company, name of company, business phone number and email.
We use this Personal Information to contact the individuals and conduct interviews about their experience as an existing or prospective customer or buyer, so that our Clients can improve their products and services.
4. STORAGE LOCATION AND TRANSFER OF PERSONAL INFORMATION
IcebergIQ processes and stores its data, including Personal Information, on servers located in Canada and the United States. IcebergIQ also transfers data to third-party service providers (“SubProcessors”) – a list can be provided to our Clients on request.
By submitting Personal Information or otherwise using the Services, you agree to this transfer, storing or processing of your Personal Information in Canada and United States. You acknowledge and agree that your Personal Information may be accessible to law enforcement and governmental agencies in Canada and the United States under lawful access regimes or court order.
5. DISCLOSURE OF PERSONAL INFORMATION WITH THIRD PARTIES
5.1 Service Providers. We may from time to time employ third parties to perform tasks on our behalf and we may need to share Client Information and other Personal Information with them to provide certain services. Prior to doing so, we will notify you and/or obtain consent as required under applicable privacy laws. Unless we tell you differently, such third parties do not have any right to use the Personal Information we share with them beyond what is necessary for them to provide the tasks and services on our behalf.
5.2 Business Transfers. If our business (or substantially all of our assets) are acquired by a third party, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information may be made available or otherwise transferred to the new controlling entity, where permitted under applicable law.
5.4 As required by law. We may disclose your Personal Information to third parties without your consent if we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, our Clients, or anyone else (including the rights or property of anyone else) that could be harmed by such activities. Further, we may disclose Personal Information when we believe in good faith that such disclosure is required by and in accordance with the law.
We also reserve the right to access, read, preserve, and disclose any information as we reasonably believe is necessary to:
· satisfy any applicable law, regulation, legal process or governmental request;
· enforce our contracts or user agreement, including investigation of potential violations hereof; and
· detect, prevent, or otherwise address fraud, security or technical issues.
The above may include exchanging information with other companies and organizations for fraud protection and spam/malware prevention. Notwithstanding the general terms of this policy, the collection, use, and disclosure of Personal Information may be made outside of the terms herein to the extent provided for in any applicable privacy or other legislation in effect from time to time, or pursuant to court orders.
7. Residents of the European Economic Area (“EEA”)
IcebergIQ processes Personal Data where the processing is necessary for the performance of a contract with our Clients, where the individual has provided consent and otherwise where the processing is necessary for the purposes of the legitimate interests pursued by us or our Clients as data controllers.
When we process Personal Data on behalf of our Clients, we are acting as the data processor and our Client is the data controller.
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. IcebergIQ aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Information (known as “Personal Data” under the EU General Data Protection Regulation). You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).
If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us by emailing email@example.com. Note that where we act as the data processor on behalf of our Clients, you will be required to contact the data controller directly to exercise your rights.
Please note that we may ask you to verify your identity before responding to such requests.
8. ACCESS, CORRECTION AND ACCURACY
You have the right to access the Personal Information we hold about you in order to verify the Personal Information we have collected in respect of you and to have a general account of our uses of that information. Upon receipt of your written request, we will provide you with a copy of your Personal Information, although in certain limited circumstances, and as permitted under law, we may not be able to make all relevant information available to you, such as where that information also pertains to another Client or individual. In such circumstances we will provide reasons for the denial to you upon request. We will endeavor to deal with all requests for access and modifications in a timely manner.
We will make every reasonable effort to keep your Personal Information accurate and up to date, and we will provide you with mechanisms to update, correct, delete or add to your Personal Information as appropriate. As appropriate, this amended Personal Information will be transmitted to those parties to which we are permitted to disclose your information. Having accurate Personal Information about you enables us to give you the best possible service.
10. ADDITIONAL INFORMATION
Unit 323 - 233 Carlaw Avenue,
Toronto Ontario Canada M4M 3N6
Email Address: [firstname.lastname@example.org]
Effective Date: Dec 19 2019