Last updated: October 15, 2019
Your privacy is very important to us. Accordingly, we have developed this policy in order for you to understand what information is collected and how it is used.
1. Personal Information Collected
When you register for the Primalogik service (the Service) we ask for information such as your name, company/organization name, and email address. Only if you register for (or upgrade to) a paid account you will be required to enter a credit card number and your billing address.
Where we provide the Service under contract with an organization (for example your employer, or a consulting firm providing you services) that organization controls the information processed by the services. For more information, please see the “Notice to End Users” section below.
2. Use of Personal Information Collected
Primalogik uses your collected information to improve the Primalogik 360 product and to respond to your customer service requests and support needs. We may occasionally contact you with product updates that we feel will improve your experience with Primalogik.
3. Web Site Navigational Information
The Primalogik 360 application and website uses Google Analytics to collect information about its visitors, but it does not track any user identifiable information through Google Analytics in accordance with Google Analytics terms and conditions.
4. Information Storage and Security
We will protect personal information by reasonable security safeguards against loss or theft, as well as unauthorized access, disclosure, copying, use or modification. Primalogik uses secure third party vendors and hosting partners to provide the necessary technology to run our services.
While we implement safeguards designed to protect your information, no security system is impenetrable and we cannot guarantee that data, during transmission through the Internet or while stored on our systems or otherwise in our care, is absolutely safe from intrusion by others.
How long we keep information
How long we keep information we collect about you depends on the type of information, as described below. After such time, we will either delete or anonymize your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible.
Account information: We retain your account information for as long as your account is active and a reasonable period thereafter in case you decide to re-activate the Service. We also retain some of your information as necessary to comply with our legal obligations, to support business operations, to enforce our agreements, to resolve disputes, and to continue to develop and improve our Service. Where we retain information for Service improvement, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our Service, not to specifically analyze personal characteristics about specific individuals.
Information you share on the Service: If your account is deactivated or disabled, some of your information and the content you have provided will remain available to allow other users to make full use of the Service. For example, we continue to display messages you sent to the users that received them and continue to display feedback you provided.
Managed accounts: If the Services are made available to you through an organization (e.g., your employer), we retain your information as long as required by the administrator of your account. For more information, see “Managed accounts and administrators” below.
Marketing information: If you have elected to receive marketing emails from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our Services, such as when you last opened an email from us. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.
5. Sharing of Personal Information Collected
Primalogik does not sell, trade, or otherwise transfer to outside parties your personally identifiable information other than for the purpose of providing the service, with the exception of when we believe the release is necessary to comply with the law.
Sharing with other Service users within your organization
When you use the Service, we share certain information about you with other Service users.
For collaboration: You can create content, which may contain information about you, and grant permission to others to see, share, edit, copy and download that content based on settings you or your administrator (if applicable) select. Some of the collaboration features of the Service display some or all of your profile information to other Service users when you share or interact with specific content. For example, when you send instant feedback to a coworker, we display your profile picture and name next to your comments so that other users with access to the feedback message understand who made the comment.
Managed accounts and administrators: If you register or access the Service using an account that is owned by your employer or organization, certain information about you including your name, profile picture, contact info, content and past use of your account may become accessible to that organization’s administrator and other Service users in the same organization. If you are an administrator for a particular organization within the Service, we may share your contact information with current or past Service users, for the purpose of facilitating Service-related requests.
Sharing with third parties
We share information with third parties that help us operate, provide, improve, integrate, support and market our Service.
Service Providers: We work with third-party service providers who provide website and application development, hosting, maintenance, backup, storage, virtual infrastructure, payment processing, analysis and other services for us, which may require them to access or use information about you. If a service provider needs to access information about you to perform services on our behalf, they do so under close instruction from us, including policies and procedures designed to protect your information.
Primalogik Partners: We work with third parties who provide consulting, sales, and technical services to deliver and implement solutions around the Service. We may share your information with these third parties in connection with their services, such as to assist with billing and collections. We may also share information with these third parties where you have agreed to that sharing.
With your consent: We share information about you with third parties when you give us consent to do so. For example, we often display personal testimonials of satisfied customers on our public websites. With your consent, we may post your name alongside the testimonial.
Compliance with Enforcement Requests and Applicable Laws; Enforcement of Our Rights: In exceptional circumstances, we may share information about you with a third party if we believe that sharing is reasonably necessary to (a) comply with any applicable law, regulation, legal process or governmental request, including to meet national security requirements, (b) enforce our agreements, policies and terms of service, (c) protect the security or integrity of our products and services, (d) protect Primalogik, our customers or the public from harm or illegal activities, or (e) respond to an emergency which we believe in good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person.
8. How to access and control your information
You have certain choices available to you when it comes to your information. Below is a summary of those choices, how to exercise them and any limitations.
You have the right to request a copy of your information, to object to our use of your information (including for marketing purposes), to request the deletion or restriction of your information, or to request your information in a structured, electronic format. Below, we describe the tools and processes for making these requests. You can exercise some of the choices by logging into the Service and using options available within the Service. Where the Service is administered for you by an administrator (see “Notice to End Users” below), you may need to contact your administrator to assist with your requests first. For all other requests, you may contact us as provided in the “Contact Us” section below to request assistance.
Your request and choices may be limited in certain cases: for example, if fulfilling your request would reveal information about another person, or if you ask to delete information which we or your administrator are permitted by law or have compelling legitimate interests to keep. Where you have asked us to share data with third parties, for example, by asking to be contacted by one of our referral partners, you will need to contact those third-party service providers directly to have your information removed.
Access and update your information: Our Service and related documentation give you the ability to access and update certain information about you from within the Service. For example, you can access your profile information from your account and search for content containing information about you using search tools in the Service. You can update your profile information within your profile page and modify information about you using the editing tools associated with your profile, provided you have the privileges necessary to perform those updates.
Deactivate your account: If you no longer wish to use our Service, your administrator may be able to deactivate your account. Please contact your administrator for assistance. If you are an administrator and are unable to deactivate an account through your administrator settings, please contact Primalogik support. Please be aware that deactivating your account does not delete your information; your information remains visible to other Service users based on your past participation within the Service.
Delete your information: Our Service and related documentation give you the ability to delete certain information about you from within the Service. For example, you can remove instant feedback messages you have entered in the system. Please note, however, that we may need to retain certain information for record keeping purposes, to make sure 360 feedback survey reports remain accurate or to comply with our legal obligations.
Request that we stop using your information: In some cases, you may ask us to stop accessing, storing, using and otherwise processing your information where you believe we don’t have the appropriate rights to do so. For example, if you believe a Service account was created for you without your permission or you are no longer an active user, you can request that we delete your account as provided in this policy. Where you gave us consent to use your information for a limited purpose, you can contact us to withdraw that consent, but this will not affect any processing that has already taken place at the time. You can also opt-out of our use of your information for marketing purposes by contacting us, as provided below. When you make such requests, we may need time to investigate and facilitate your request. If there is delay or dispute as to whether we have the right to continue using your information, we will restrict any further use of your information until the request is honored or the dispute is resolved, provided your administrator does not object (if applicable).
Opt out of communications: You may opt out of receiving promotional communications from us by using the unsubscribe link within each email, updating your email preferences within your Service account settings menu, or by contacting us as provided below to have your contact information removed from our promotional email list or registration database. Even after you opt out from receiving promotional messages from us, you will continue to receive transactional messages from us regarding our Service.
Data portability: Data portability is the ability to obtain some of your information in a format you can move from one service provider to another (for instance, when you transfer your mobile phone number to another carrier). Depending on the context, this applies to some of your information, but not to all of your information. Should you request it, we will provide you with an electronic file of your basic account information and the information you create on the spaces you under your sole control, like your personal performance appraisal results.
9. How we transfer information we collect internationally
International transfers of information we collect
We collect information globally and primarily store that information in the United States and Canada (note that as of November 30th 2019, data will be stored exclusively in Canada). We transfer, process and store your information outside of your country of residence, to wherever we or our third-party service providers operate for the purpose of providing you the Service. Whenever we transfer your information, we take steps to protect it.
International transfers within Primalogik: To facilitate our global operations, we transfer information to either Canada or the United States and allow access to that information from countries in which the Primalogik owned or operated companies have operations for the purposes described in this policy. These countries may not have equivalent privacy and data protection laws to the laws of many of the countries where our customers and users are based. When we share information about you within and among Primalogik corporate affiliates, we make use of standard contractual data protection clauses, which have been approved by the European Commission. Note: This provision will be retired on November 30th 2019. As of that date Primalogik data will be stored exclusively in Canada.
10. Notice to End Users
Our products are intended for use by organizations. Where the Service is made available to you through an organization (e.g. your employer), that organization is the administrator of the Service and is responsible for the accounts and/or organization over which it has control. If this is the case, please direct your data privacy questions to your administrator, as your use of the Service is subject to that organization’s policies. We are not responsible for the privacy or security practices of an administrator’s organization, which may be different than this policy.
Administrators are able to:
- require you to reset your account password;
- restrict, suspend or terminate your access to the Service;
- access or retain information stored as part of your account;
- restrict, suspend or terminate your account access;
- change the email address associated with your account;
- change your information, including profile information;
- restrict your ability to edit, restrict, modify or delete information
In some cases, administrators can also:
- access information in and about your account.
Please contact your organization or refer to your administrator’s organizational policies for more information.
11. Contact Us
Primalogik Software Solutions Inc.
3 Place Ville Marie, Suite 400
Montreal (Quebec) Canada H3B 2E3