Last updated and effective as of October 19, 2020
This Policy sets out what Personal Data we collect, how we process it and how long we retain it. This Policy applies to all of our processing activities where we act as a data controller. In this policy, "we", "us" and "our" refers to Rally Technologies Inc., a company incorporated in Canada with its incorporation number 12012782 Canada Inc. For more information about us, see the Contact Us section of this policy.
In this Policy , “personal data” means any information relating to you as an identified or identifiable natural person (“Data Subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an online identifier or to one or more factors specific to your physical, physiological, genetic, mental, economic, cultural or social identity.
Please feel free to jump to the relevant section:
• How we collect information from you
• What type of information is collected?
• How we use your personal information
• How long we keep your information for
• Your individual rights
• Sharing your personal information
• Keeping your information safe
• Additional Information
We collect information about you when you:
• Visit our website;
• Contact us either through our website or through other direct means of electronic communication;
• When you sign up to our newsletter;
• Enter into a contract with us;
• Use our services or offerings (including our web app); and/or
• Enter into any other relationship with us or interact with us or our services.
The personal information we collect might include your: Name; address; email address; geolocation; country of residence; social media profiles; IP address; the type of device through which you browse our website or use our services or app including the operating system, your location, time date and duration of your visit to our website and previous visits to our website. If you are a paying customer we may collect your credit card details or other payment processing information.
We use personal information about you in connection with the following purposes:
Provision of services and management:
• to provide you with the information, products and services that you have requested from us;
• to complete any transaction you are undertaking with us;
• to manage and operate your account to use our services;
• to perform a contractual obligation we have to you; and/or
• to meet a legal or regulatory obligation.
• to ensure that content from our site and app is presented in the most effective manner for you;
• to administer our site & app and for internal business administration and operations, including troubleshooting, data analysis, testing,
research, statistical and survey purposes;
• to notify you about changes to our service;
• as part of our efforts to keep our site safe and secure;
• to provide you with information about other services we offer that are similar to those that you already have or have enquired about;
• to provide you with other marketing material such as our Newsletter.
If you do not want your personal information to be used for marketing purposes, please contact us on the above details.
We do not use automated-decision making methods (including profiling). This means decisions are not made by robots or computers, and therefore not ‘automated’. However, certain third parties may use certain automated decision-making tools or software. We are not responsible for the privacy practices of others and will take reasonable steps to bring such automated decision-making to your attention, but you are encouraged to become familiar with the privacy practices of any third parties you enter into any agreements with.
We also use LocalStorage, which works in a similar way to cookie, but stores a larger file onto your device which helps our websites and apps function. The use of LocalStorage is a necessary function when using our app which cannot run without the use of LocalStorage.
In addition to the uses of cookies described above, these entities may use other methods, such as the technologies described below, to collect information about your use of our website and other websites and online services. These are:
Pixels tags: Pixel tags (which are also called clear GIFs, web beacons, or pixels), are small pieces of code that can be embedded on websites and emails. Pixels tags may be used to learn how you interact with our website pages and emails, and this information helps us and our partners provide you with a more tailored experience.
Device Identifiers: A device identifier is a unique label that can be used to identify a mobile device. Device identifiers may be used to track, analyse and improve the performance of the website and ads delivered.
We use the following third party processors:
We use Google Analytics to analyze the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website.
We do not store the information collected by Google Analytics and this is stored by them.
We use Fullstory to analyse the use of our website. The information gathered relating to our website is used to create reports about the use of our website.
We do not store the information collected by fullstory and this is stored by them.
We use Amplitude to analyse the use of our website. The information gathered relating to our website is used to create reports about the use of our website.
We do not store the information collected by Amplitude and this is stored by them.
We use Cotter for our account creation. The information gathered relating to our website is used to create accounts for hosts so they can use our website.
We do not store the information collected by Cotter and this is stored by them.
We use Intercom for our support and certain marketing campaigns. The information gathered relating to our website is used to help people browse our application and learn more about our features.
We do not store the information collected by Intercom and this is stored by them.
We use Segment as a data warehouse for our website. The information gathered relating to our website is used to create reports about the use of our website.
We do not store the information collected by Segment.
Retention periods are determined based on the type of record, the nature of the record and activity and the legal or regulatory requirements that apply to those records. Typically, personal data which is collected are retained for 5 years. Where personal data is collected pursuant to a contract or prior to the creation of a contract, these are retained for 6 years after the termination of the contract pursuant to our legitimate interests in defending any legal claims which may be brought against us.
However, we may retain your personal data for a longer period of time where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person or where we have a legitimate interest to do so.
We may pass your information to our Business Partners, administration centres, third party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing our services to you.
In addition, when we use any other third party service providers, we will disclose only the personal information that is necessary to deliver the service required and we will ensure, via contractual obligations, that this requires them to keep your information secure and not to use it for their own direct marketing purposes.
In addition, we may transfer your personal information to a third party as part of a sale of some, or all, of our business and assets or as part of any business restructuring or reorganisation, or if we are under a duty to disclose or share your personal data in order to comply with any legal obligation. However, we will take steps to ensure that your privacy rights continue to be protected.
Transferring your information outside of the European Economic Area (for EEA Clients)
We may share your personal data with third party companies where we have a legal basis for doing so such as to provide you with our services or because we ourselves use service providers outside of EEA in order to operate our business. If we transfer your information outside of the EEA to third parties we will take steps to ensure that your privacy rights continue to be protected as outlined in this Policy. This may require us to take certain additional steps to ensure that appropriate safeguards are in place if that third country is not deemed by the European Commission to offer an adequate level of protection for your privacy rights, which may include use of contractual safeguards to allow you to be able to enforce your rights and ensure these are preserved. In certain circumstances, we may need to ask you for your explicit consent to such third country transfers, and will always do so in writing and giving you full information about why we need your consent and your right to withdraw that consent at any time (together with the consequences of withdrawal).
You have certain rights under applicable legislation, and in particular under Regulation EU 2016/679 (General Data Protection Regulation or ‘GDPR’), for European users. We explain these below. You can find out more about the GDPR and your rights by accessing the European Commission’s website.
Right Information and access
Right to rectification
You have the right to have any inaccurate personal information about you rectified and to have any incomplete personal information about you completed. You may also request that we restrict the processing of that information. The accuracy of your information is important to us.
Right to erasure (right to be ‘forgotten’)
You have the general right to request the erasure of your personal information in the following circumstances:
• the personal information is no longer necessary for the purpose for which it was collected;
• you withdraw your consent and no other legal justification for processing applies;
• you object to processing for direct marketing purposes;
• we unlawfully processed your personal information;
• and erasure is required to comply with a legal obligation that applies to us.
We will proceed to comply with an erasure request without delay unless continued retention is necessary for:
• Exercising the right of freedom of expression and information;
• Complying with a legal obligation under EU or other applicable law;
• The performance of a task carried out in the public interest;
• Archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes, under certain circumstances;
• and/orThe establishment, exercise, or defence of legal claims.
Right to restrict processing and right to object to processing
You have a right to restrict processing of your personal information, such as where:
• you contest the accuracy of the personal information;
• where processing is unlawful you may request, instead of requesting erasure, that we restrict the use of the unlawfully processed personal information;
• we no longer need to process your personal information but need to retain your information for the establishment, exercise, or defence of legal claims.
You also have the right to object to processing of your personal information under certain circumstances, such as where the processing is based on your consent and you withdraw that consent. This may impact the services we can provide and we will explain this to you if you decide to exercise this right.
Right to data portability
Where the legal basis for our processing is your consent or the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, you have a right to receive the personal information you provided to us in a structured, commonly used and machine-readable format, or ask us to send it to another person.
Right to freedom from automated decision-making
As explained above, we do not use automated decision-making, but where any automated decision-making takes place, you have the right in this case to express your point of view and to contest the decision, as well as request that decisions based on automated processing concerning you or significantly affecting you and based on your personal data are made by natural persons, not only by computers.
Right to object to direct marketing (‘opting out’)
You have a choice about whether or not you wish to receive information from us. We will not contact you for marketing purposes unless:
you have a business relationship with us, and we rely on our legitimate interests as the lawful basis for processing (as described above)
you have otherwise given your prior consent (such as when you download one of our guides)
You can change your marketing preferences at any time by contacting us on the above details. On each and every marketing communication, we will always provide the option for you to exercise your right to object to the processing of your personal data for marketing purposes (known as ‘opting-out’) by clicking on the ‘unsubscribe’ button on our marketing emails or choosing a similar opt-out option on any forms we use to collect your data. You may also opt-out at any time by contacting us on the below details.
Right to request access
You also have a right to access information we hold about you. We are happy to provide you with details of your Personal Information that we hold or process. To protect your personal information, we follow set storage and disclosure procedures, which mean that we will require proof of identity from you prior to disclosing such information. You can exercise this right at any time by contacting us on the above details.
Right to withdraw consent
Where the legal basis for processing your personal information is your consent, you have the right to withdraw that consent at any time by contacting us on the above details.
Raising a complaint about how we have handled your personal data
If you wish to raise a complaint on how we have handled your personal data, you can contact us as set out above and we will then investigate the matter.
Right to lodge a complaint with a relevant supervisory authority
If we have not responded to you within a reasonable time or if you feel that your complaint has not been resolved to your satisfaction, you are entitled to make a complaint with the supervisory authority in the country of your habitual residence, place of work, or the place where you allege an infringement of one or more of our rights has taken place, if that is based in the EEA.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Review of this Policy
We may make changes to this Policy from time to time. Where we do so, we will notify those who have a business relationship with us or who are subscribed to our emailing lists directly of the changes, and change the ‘Last updated’ date above. We encourage you to review the Policy whenever you access or use our website to stay informed about our information practices and the choices available to you. If you do not agree to the revised Policy, you should discontinue your use of this website.
Rally Technologies Inc., Attention: Privacy Officer
336 Dundas St West, M5T1G5
If, having shared your concerns with us, you are still not satisfied, you may file a complaint with the Office of the Privacy Commissioner of Canada by mail at 30 Victoria Street Gatineau, Quebec K1A 1H3 or by calling 1-800-282-1376.