TownSuite

TownSuite Municipal Software Inc. (hereafter, “TownSuite”, “We”, “Us”, or “Our”) respects the privacy of all of its users and is committed to protecting your personal information in accordance with this Privacy Policy and applicable Canadian privacy laws. This Privacy Policy applies to the use of our proprietary TownSuite Municipal Software; and all affiliated applications, add-ons and modules (collectively the “Product”) by you, any employees, representatives, agents or third-parties who are authorized by the Licensee under the End-User License Agreement to use the Product.

Your personal information is information about you as an identifiable individual including, but not limited to, your name, mailing address, email address, birth date, and gender.

This Privacy Policy governs your access to our Product as a registered user. By using our Product, you consent to the collection, use, disclosure, and other uses of personal information pursuant to this Privacy Policy.

Our Privacy Policy incorporates, as standards, the principles outlined in Schedule I of the Personal Information Protection and Electronic Documents Act (Canada) as outlined below.

Ten Privacy Principles of Fair Information Practices

Principle 1 - Accountability

We are responsible for personal information under Our control and to this end We have appointed a Privacy Officer who is accountable for Our compliance with this Privacy Policy and applicable privacy laws. The contact information for the Privacy Officer is outlined at the end of this Privacy Policy.

Principle 2 – Identifying Purposes

We will identify the purposes for collecting personal information prior to or at the time it is collected. We will also obtain your consent before your personal information is used or disclosed for a new purpose unless such use or disclosure is permitted without your consent pursuant to applicable privacy laws or this Privacy Policy.

Principle 3 – Consent

Unless an exemption applies under applicable privacy laws, your knowledge and consent is required for the collection, use, or disclosure of personal information. If you use or register to use the Product, request information about the Product from Us, or otherwise provide your personal information to Us, you consent to the collection, use, disclosure and management of your personal information in accordance with this Privacy Policy. You may withdraw your consent by writing to the Privacy Officer identified at the end of this Privacy Policy.

Principle 4 – Limiting Collection

We will limit the collection of personal information to that which is necessary for the purposes identified by Us in this Privacy Policy or otherwise identified at the time of collection. We will collect personal information by fair and lawful means.

Principle 5 – Limiting Use, Disclosure, and Retention We will only use or disclose your personal information for the purpose for which it was collected except with your consent or as permitted by law. Personal information will only be retained as long as necessary for the fulfillment of such purposes.

Principle 6 – Accuracy

We will keep personal information as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.

Principle 7 – Safeguarding Customer Information

We protect personal information with safeguards appropriate to the sensitivity of the information by maintaining appropriate and commercially reasonable physical, procedural and technical security with respect to its offices and information storage facilities so as to prevent any loss, misuse, unauthorized access, disclosure, or modification of personal information. However, we cannot guarantee that such security measures will be sufficient and will not be breached, and your information may not be disclosed or otherwise accessed in an unauthorized manner. We keep the personal information that We collect about you strictly confidential. Only authorized personnel have access to this personal information. We cannot guarantee that any personal information that you may choose to disclose via the internet will not be intercepted by third parties. We assume no responsibility for personal information disclosed through the internet, which is intercepted, diverted or otherwise accessed.

Principle 8 – Openness

For further information on Our personal information, management policies and practices, please contact the Privacy Officer identified at the end of this Privacy Policy.

Principle 9 – Individual Access

You can ask to view your personal information held by Us by writing to the Privacy Officer identified at the end of this Privacy Policy. Where necessary you can request that corrections be made where you can show that the personal information about you held by Us is incorrect or incomplete.

Principle 10 – Challenging Compliance

You are able to address and challenge Our compliance with the above principles and this Privacy Policy by contacting the Privacy Officer identified at the end of this Privacy Policy or under applicable law.

What information do we collect?

We collect various types of personal information from you as a user of the Product, including but not limited to when have used the Product and associated device information, how you use our Product, the modules and add-ons you have utilized, the processes and functionality of the Product that you have utilized, the frequency and duration of your activities, information regarding management of your data and the like.

If you provide personal information to us, including personal information about individuals other than yourself, you represent and warrant that:

1. You have the authority to provide that personal information and to grant us the right to use that personal Information consistently with this Privacy Policy;
2. You have provided that personal information voluntarily; and
3. You consent to the collection, use and disclosure of that personal information in the manner indicated by this Privacy Policy.

Registration

In order to use the Product, you will need to register for an account and sign in. When you register you may be asked for, including but not limited to, your full name and e-mail address, mailing address, and phone number. You may create a password for your account. The name and e-mail address you include on your profile may be viewable by other users of the Product.

IP Addresses

When you use the Product, whether you are signed into your account or not, your IP address will be collected by trusted third parties for web traffic, reporting, analytics (e.g. session length, pages visited, network location), statistics, analysis, and other like purposes.

What is the information used for?

Any of the information We collect from you may be used in one of the following ways:

1. To validate your registration and to create and administer your account;
2. To enforce or apply the End-User License Agreement with respect to the Product;
3. To personalize your experience (your information helps Us to better respond to your individual needs);
4. To improve the Product (We continually strive to improve Our Product offerings based on the information and feedback We receive from you);
5. To perform analytics, conduct research, and monitor and analyze trends, usage and activities in connection with the Product;
6. To improve customer service (your information helps Us respond more effectively to your customer service requests and support needs);
7. To protect Us and you from error and fraud;
8. To send periodic emails (the email address you provide for registration may be used to send you information and updates pertaining to your use of the Product, in addition to receiving occasional company news, updates, information on third parties that We feel may be of interest to you, etc);
9. If required, to co-operate with law enforcement authorities, to comply with a court order or to prevent a breach of any applicable law;
10. To establish and maintain commercial relations with you and provide you with ongoing service;
11. To understand your individual needs, interests and eligibility for other products and services;
12. To analyze for the purposes of improving and developing other products and services;
13. To provide you with information on products, services, offers or other information from us that We feel may be of interest to you. If at any time you wish to end Our communication with you, contact the Privacy Officer identified at the end of this Privacy Policy; and
14. To meet legal or regulatory requirements.

If you do not want Us to use your personal information, receive any special offers or communications from Us, or wish to confirm that your personal information has been accurately recorded or correct such information, you should email the Privacy Officer identified at the end of this Privacy Policy.

Do we disclose Personal Information to outside parties?

We will only disclose, and you consent to such disclosure, your personal information to third parties as follows:

1. Where you have specifically given Us your consent to disclose your personal information for a designated purpose;
2. To those who are acting on Our behalf as employers, agents, suppliers or service providers to enable Us to provide you with use of the Product, and in relation to our efforts to better understand your needs and develop, enhance, market or provide products and services. Such entities act under contractual controls, requiring them to maintain the confidentiality of your personal information and to use such information solely for the purposes for which the personal information was originally collected;
3. As required by law, including by any order of any court, institution or body with jurisdiction or authority to compel the production of information, or in order to protect or defend a legal interest. We may also disclose personal information to a collection agency for the express purpose of the collection of past due bills;
4. If We believe your actions are inconsistent with the spirit or language of our End-User License Agreement or policies, or to protect the rights, property and safety of TownSuite or others; and
5. In connection with a corporate reorganization, merger or amalgamation with another entity, or a sale of all or substantially all of Our assets provided that the personal information disclosed continues to be used for the purposes permitted by this Privacy Policy by the entity acquiring the information.

Information which is not personal information may be provided to other parties for marketing, advertising, or other uses. We will not sell, trade, or otherwise transfer to outside parties your personal information.

Changes to our Privacy Policy

If We decide to change this Privacy Policy, we will notify you of the revised Privacy Policy via email. By you continuing to use the Product after those changes become effective, you agree to be bound by the revised Privacy Policy.

This Privacy Policy version was updated on April 21, 2021

Privacy Officer Contact

If there are any questions regarding this Privacy Policy you may contact the Privacy Officer at the information below.

TownSuite Privacy Officer
216 AIRPORT BLVD
GANDER, NL CANADA
A1V 1L6
[email protected]