This Policy may be updated periodically to reflect changes to our personal information practices. We strongly encourage you to refer to this Policy often for the latest information about our personal information practices. The last revision date of this policy is found at the end of this page.
We ask our users for only the information needed for us to be able to provide the Services our users expect of us.
Inquiries or Concerns?
If you have any questions or concerns about our Policy, how it might apply to you, or if it does apply to you, please contact our Information Security Officer. You can:
(i) send an e-mail to [email protected], or
(ii) notify us by mail at SideDrawer Inc., 100 King Street, Suite 3400, 1 First Canadian Place, Toronto, Ontario, M5X 1A4.
Your use of the Website, the App or the Services means that you agree to our collection, use, and disclosure of the information you share with us, as explained in this Policy. If you do not agree with this Policy, or the terms of service, please do not use the Website, the App or the Services.
What Is Personal Information?
For the purposes of this Policy, “Personal Information” is any information that describes you as an identifiable individual. Personal Information does not include your business title or business contact information when used or disclosed for the purpose of business communications.
What Kind Of Personal Information Do We Collect?
You can visit the Website without directly telling us who you are. However, it is important to note that our web server collects information related to your visit to the Website, including the IP address and domain used to access the Services, the type and version of your browser, the website you came from to access the Services, the page you entered and exited at, any pages that are viewed by that IP address and the country from which you accessed the site.
We use this information to monitor the performance of the Services (such as number of visits, average time spent per page, number of page views), to determine interest in the Services, and for business purposes, such as working to continually upgrade the Services to meet consumer needs.
In order to use our App, we will collect personal information that you submit to us, such as your name, address, phone number, e-mail address, gender, marital status, your credit card information (for third party payment processing), and your designates’ names, your relationship with your designates, your designates’ phone number and e-mail addresses, contact information such as name, phone number and e-mail address of your professionals or service providers that you submit to us, name, phone number and e-mail address of any recipients that you submit to us, and any other contact or other information that you choose to provide by:
(i) registering as a user on our App;
(ii) uploading documents, submitting photographs, or location addresses to us;
(iii) contributing data, or preferences to the Website or the App;
(iV) corresponding with us via e-mail using the hyperlinks created for that purpose; or
(V) through other communication methods.
We collect this information to be able to identify a user, verify their information and be able to provide access safeguards in order to limit access to their account. We provide the ability to upload and submit documents, photographs and location addresses so that it can be used to inform your designates and recipients of the existence and whereabouts of these documents, belongings and assets should the need arise. This is the core of our service offering, and not providing this information may limit the value of our service to you. We also collect credit card information so that our third-party payment processing partners can charge you for the services we provide to you, either through transactions or subscription
Note that SideDrawer does not read or review the documents or the photographs submitted to us, except where we are required to do so by law or if we have reason to believe the Website or the App is being used for unauthorized purposes. We use AES-256 encryption that does not allow us to read or access your documents or photographs. Any documents that you upload are encrypted and kept on a cloud storage service in an encrypted fashion hosted by a leading global cloud hosting provider. We have taken steps to ensure there are more than adequate safety controls around these documents, but you must be aware that nothing is 100% secure and there is always risk of unauthorized access.
How Do We Collect Personal Information?
As a general rule, SideDrawer collects personal information directly from you. In most other circumstances where the personal information that we collect about you is held by a third party, we will obtain your permission before we seek out this information from such sources (such permission may be given directly by you, or implied from your actions).
From time to time, we may utilize the services of third parties and may also receive Personal Information collected by those third parties in the course of the performance of their services for us or otherwise. Where this is the case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your Personal Information to us.
From time to time, we may obtain your consent to send you email, SMS text messages and other communications about SideDrawer products or events that may be of interest to you. You can opt-out of receiving marketing and promotional email from us by following the unsubscribe instructions contained
in each of our email communications. Please note that you will continue to receive email regarding your account and transactions with us. Alternatively, you can unsubscribe from any of our marketing communications by contacting us at [email protected]
If you inquire about or apply for a job with SideDrawer, you may provide us with certain Personal Information about yourself (such as the information contained in a resume, cover letter, or similar employment-related materials). We use this information for the purpose of processing and responding to
your application for current and future career opportunities.
When you visit the Website or use the Services, we may place a “cookie” on the hard drive of your computer or mobile device to track your visit. A cookie is a small data file that is transferred to your hard drive through your web browser that can only be read by the website that placed the cookie on your hard drive. The cookie acts as an identification card and allows the Website to identify you and to record your passwords and preferences. The cookie allows us to track your visit to the Website, App or Services so that we can better understand your use of the Services and customize and tailor it to better meet your needs. For example, our cookies help us to learn about the usage of the Services by helping us to track
how many visitors we have, how often they visit various sections of the Services, and their geographic location.
Most web browsers are set to accept cookies. However, on most web browsers you may change this setting to have your web browser either: (1) notify you prior to a website placing a cookie on your hard drive so that you can decide whether or not to accept the cookie; or (2) automatically prevent the placing of a cookie on your hard drive. It should be noted that if cookies are not accepted, you will not be able to access a number of web pages found on the Website.
Why Do We Collect and Use Personal Information?
In order to provide the services and value derived from using the Website, the App or the Services, we need to collect and process information about you. In particular, we collect Personal Information from you in order to:
- 1. establish, maintain and manage our relationship with you;
3. review and improve the products and services that we provide to you;
4. comply with your requests;
5. notify you of products or services in which you may be interested;
6. allow our partners to be able to fulfill their legal and regulatory requirements of collecting sufficient information so as to be able to meet our obligations to you as a customer. For example, our third-party payment processing provider is required to comply with various financial regulatory bodies before they can charge your credit card, and as such we have to share your information with them in order to complete any transactions you enter in with us;
7. protect us against error, fraud, theft and damage to our goods and property; and
8. comply with applicable law or regulatory requirements.
Additionally, we collect Personal Information for specific purposes that we may advise you of, at or before, the time that we collect such Personal Information.
We may also use your contact information to provide you with notification regarding the Services, such as any future amendments to this policy, and may disclose such information in response to law enforcement agencies or other public agencies, or if we feel that such disclosure may prevent the
instigation of a crime, facilitate an investigation related to public safety, protect the security or integrity of the Services, or enable us to take precautions against liability.
Information SideDrawer Typically Does Not Collect (But Sometimes Might)
While we may charge a fee now or in the future for use of certain aspects of our Services, your valid credit card number, type, expiration date, name and billing address (collectively, “Payment Information”) is collected, stored, used and processed by Stripe Inc. (“Stripe”), our third-party payment
sometimes we may request and receive some of your Payment Information from Stripe in order to complete certain transactions you initiated through the Services, to enroll you in a discount or other rebate program you elected to participate in, to protect against or identify potentially fraudulent transactions, or otherwise as necessary to manage our business.
Accordingly, sometimes we may obtain Payment Information pertaining to you as a result of your use of the Services; however, you can rest assured that we will only use any such Payment Information we obtain in furtherance of the Services.
Who Do We Share Your Personal Information With?
Your Personal Information may be shared with our employees, contractors, consultants, affiliates and other third parties who require such information to assist us with establishing, maintaining and managing our relationship with you, notifying you of products or services in which you may be interested, or developing, operating and maintaining the Services. In addition, your Personal Information may be disclosed or transferred to another party in the event of a change in ownership of, or a grant of a security interest in all, or a part of, SideDrawer.
For example, as a user, you have the ability to voluntarily disclose the information you have provided to us to a designate of your choosing through our customized automated reports. SideDrawer will not be held accountable if you disclosed this information in error, accidentally, unintentionally or had entered the wrong contact information of your intended designate. As a procedure, SideDrawer will only release the information to your designates after they have verified their acceptance of their role as a designate for you. SideDrawer does not take any steps to verify that the e-mail address of your designate is truly your intended designate, or that their relationship as you have indicated is truly the case. We simply record
your and your designates’ information as entered. Please ensure that any contact information you have entered is correct. It is your responsibility to verify that your information, your designates’ information as we have it recorded in our system, and your recipients’ information is current and complete. SideDrawer will on occasion confirm and re-confirm the designates role, and your choice of designates, but will not
take any steps to confirm the relationship or whether that designates information is who you intended it to be.
Another example is that our secure billing service provider may provide certain information technology and data processing services to us from time to time so that we may operate our business. As a result, your Personal Information may be collected, used, processed, stored or disclosed in the United States of America, Canada and/or any other relevant locations. Further, your Personal Information may be disclosed:
- as permitted or required by applicable law or regulatory requirements (for example, in response to a court order or a subpoena);
2. to protect the rights and property of SideDrawer;
3. during emergency situations or where necessary to protect the safety of a person or group of persons;
4. where the Personal Information is publicly available; or
5. with your consent.
You acknowledge and agree that access to and use of the Services is provided via the Internet and that your information, including Personal Information, may be transferred across national borders and stored or processed in any country in the world.
We may also collect, use or disclose your Personal Information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.
How Do We Protect Your Personal Information?
SideDrawer endeavors to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the Personal Information in question. These safeguards are designed to protect your Personal Information from loss and unauthorized access, copying, use, modification or disclosure. For example, we take the following measures:
(i) We use AES 256-bit encryption for data at storage and AES 128-bit encryption for data during transmission
(ii) We limit our own access to your personal information by ensuring that only authorized persons have access and such access requires a secure password. Only employees who “need to know” in order to fulfill their job requirements have access to your personal information; and
(iii) We train our employees to keep clients’ Personal Information private and confidential.
The security of your Personal Information is important to us. Please immediately advise us at [email protected] or [email protected] of any incident involving the loss of or unauthorized access to or disclosure of Personal Information that is in our custody or control.
Unfortunately, no data transmission is 100% secure. As a result, while we strive to protect your Personal Information, we cannot guarantee the confidentiality or security of any information you transmit to us, and you do so at your own risk.
How Can You Protect Your Information?
It is important to remember that while we take steps to protect your Personal Information and the integrity of the Services that you sign up to enjoy, no security measures are perfect or impenetrable. In addition, whenever you voluntarily disclose Personal Information in public, that information can be collected and used by others. SideDrawer is not responsible for the collection, usage or disclosure of your Personal Information by third parties to whom you voluntarily disclose such information.
Keeping Your Information Up To Date
It is important that your Personal Information contained in our records is both accurate and current. If your Personal Information happens to change during the course of our relationship, please keep us informed of such changes.
In addition, the value of our services is to ensure the information you provide to us is current and complete. If specifics related to your personal records, information, location of your items, photographs, documents, policies, or any other information changes, you are expected to reflect those changes on the App so that you and your designates have the most current and correct information, when and if you
decide to share or release your information to them.
In some circumstances, we may not agree with your request to change your Personal Information and may instead append an alternative text to the record in question.
What If You Want To See Your Personal Information?
You can ask to see your Personal Information. If you want to review, verify or correct your Personal Information, please contact us as listed at the top of the Policy.
Your right to access the Personal Information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the Personal Information that we hold about you. In addition, the Personal Information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices
as required or permitted by applicable law.
In the event that we cannot provide you with access to your Personal Information, we will endeavor to inform you of the reasons why, subject to any legal or regulatory restrictions
How Do We Apply and Interpret This Policy?
It is our policy to comply with the privacy legislation within each jurisdiction in which we operate. Sometimes the privacy legislation and / or an individual’s right to privacy are different from one jurisdiction to another. This Policy has a limited scope and application. Consequently, the rights and obligations contained in this Policy may not be available to all individuals or in all jurisdictions.
Any interpretation associated with this Policy will be made by our Board of Directors or the management team of our organization. This Policy includes examples, but is not intended to be restricted in its application to such examples, therefore where the word ‘including’ is used, it shall mean ‘including without limitation’.
This Policy does not create or confer upon any individual any rights, or impose upon SideDrawer any rights or obligations outside of, or in addition to, any rights or obligations imposed by applicable laws. Should there be, in a specific case, any inconsistency between this Policy and such laws, this Policy shall be interpreted, in respect of that case, to give effect to, and comply with, such laws.
What Happens If We Disagree?
We hope we won’t! This Policy covers only those activities that are subject to the provisions of Canada’s Federal and provincial privacy laws, as applicable. This Policy does not create or confer upon any individual any rights, or impose upon SideDrawer any rights or obligations outside of, or in addition to, any rights or obligations imposed by Canada’s Federal and provincial privacy laws, as applicable. Should
there be, in a specific case, any inconsistency between this Policy and Canada’s Federal and provincial privacy laws, as applicable, this Policy shall be interpreted, in respect of that case, to give effect to, and comply with, such privacy laws. Any dispute will be governed by the laws of Ontario and the laws of Canada.
Will We Modify This Policy?
From time to time, we may make changes to this Policy to reflect changes in our legal or regulatory obligations or in the manner in which we deal with your Personal Information. We will post any revised version of this Policy on the Website and we encourage you to refer back to it on a regular basis. This Policy was last updated on February 13, 2019.