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Last update: January 18, 2021

 

This privacy policy (“Privacy Policy”) describes how The Croo Group Inc. (“Croo,” “we,” or “us”) collects, uses, and discloses your personal information, and the steps we take to protect it. If you have any questions regarding our privacy practices, please contact us.

 

For the purposes of this Privacy Policy, all references to Croo shall be deemed to include its related companies (including all subsidiaries), its divisions and other companies that are part of its corporate group, its suppliers and licensors, as well as its employees, directors, administrators, shareholders, agents, subcontractors and other representatives.

 

This Privacy Policy applies to our websites, including https://www.croo.io (the “Websites”), to the Croo managed cloud communication system and related software solutions, and any other services offered by Croo (together with the Websites, the “Services” and each one of them is a “Service”). Croo and its affiliates may share information with each other and use it in a manner consistent with this Privacy Policy.

 

In addition to this Privacy Policy, your use of the Services is also subject to other terms that may be communicated by Croo to you from time to time.

 

If you do not agree to comply with these terms and conditions regarding our collection, use, communication, sharing, and management of personal information set out in this Privacy Policy, please do not use the Services and cease using them immediately.

 

PERSONAL INFORMATION THAT IS COLLECTED

 

Personal information is generally defined by applicable privacy or data protection laws as information about an identifiable individual. An identifiable individual is one who can be identified directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or by one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.

 

You may choose to give us personal information when you use our Services or access certain functions of a Service. This information may include your name, phone number, e-mail address, postal address, company name, billing and shipping information, date of birth and other relevant information about you or your company.

 

Other personal information is automatically collected when you use our Websites, including your IP address, the domain name and host from which you access the internet, the pages of a Website that you visit, your browsing history, your browser software or operating system and your browser’s country setting.

 

We use the personal information described above for legitimate purposes which are detailed in the next section.

 

COLLECTION AND USE OF PERSONAL INFORMATION

 

We collect personal information that you provide when you use or access certain functionalities of our Services, including when you participate in the following activities:

 

* Consulting the content on our Websites.

* Ordering or purchasing our Services.

* Registering for, providing and administering the Services.

* Requesting technical support.

* Subscribing to our mailing list, newsletter and email communication in order to receive our latest news.

* Communicating with us to ask a question, submit a comment or file a complaint (customer service).

* Management database and customer relationship management (CRM).

* Promotions or contests.

* Applying for a job with Croo.

 

In general, the personal information that is collected is used to administer and deliver the Services. To help you better understand how your personal information will be used, you will find below a more detailed explanation on how your personal information will be used in relation to specific activities.

 

Consulting the content on our Websites. Our Websites provide the possibility to view and request information on the products and services offered by Croo. When consulting the information on our Websites, we will collect and store information regarding your use of the Websites including but not limited to (i) the pages visited, (ii) the information viewed and (iii) the date and time of access.

 

Ordering or purchasing our Services. When you order a Service, or request a quote, by communicating with us through a Website form, e-mail or other means, we will use the personal information that is collected to process your request, to complete your transaction using the payment services offered by our preferred third-party payment services provider and when applicable, to deliver any information you may request on the Service.

 

Registering for, providing and administering the Services. You may be required to register and create a user account which will be used to verify your identity when you access a Service. We will also use your personal information that is collected to notify you about the administration of your user account and to allow use of those features on the Service that are reserved to certain account holders. Furthermore, we will collect information about your use of a Service to enable certain product features to operate, to improve the user experience, to generally improve and develop our Services, to inform our clients on the overall use of the Service and to provide training and support, to send technical notices, updates and security alerts.

 

Technical Support. If you require technical support for a Service, we will collect your name, company name, title, phone number and business address. This information is used to allow us to contact you and to provide you with the technical support.

 

Subscribing to our mailing list, newsletter and email communication. Sometimes, we may collect personal information to send you emails containing our latest news, products, services or promotions as well as those of third parties to whom we are linked. You can unsubscribe from our mailing list at all times by following the instructions provided at the end of every email. You can also unsubscribe from our mailing list by following the instructions set out in the section titled “Contact us” below. Your request will be processed within the statutory timeframes.

 

Communicating with us to ask a question, submit a comment or file a complaint (customer service). If you choose to send us an electronic feedback form or to send comments, questions or feedback via email, we collect some personal information as well as your comments, suggestions and feedback. This personal information is used to respond to your comments, questions or feedback. We can also keep this information to help you in the future. We can also use your comments, suggestions and feedback to monitor and/or enhance our products and service offerings and our Services.

 

Management database and customer relationship management (CRM). When you participate in one of the above-mentioned activities, we collect personal information provided to complete and update our customer relationship database. In this context, the personal information collected is used to manage the relationship with customers, to generate mailing lists, to follow up with potential clients and to create internal reports on relationships between Croo and its clients to monitor and/or enhance our Services.

 

Promotions or contests. When you participate in a campaign, referral promotion, or online contest, giveaway, promotion or special offer, we collect personal information about you in order to manage the campaign, promotion, contest or special offer. We use the personal information collected to communicate with or notify you about the campaign, promotion, contest or special offer, award prizes and generally to manage your participation.

 

Applying for a job with Croo. When you apply for a job with Croo, either online or otherwise, we collect personal information about you as set out in your application. We use that personal information in order to evaluate and process your application and your interest in employment with us, to communicate with you about your application, and to manage our recruitment needs.

 

INFORMATION COLLECTED AUTOMATICALLY

 

Consulting the content on the Websites. When you browse our Websites, information pertaining to your user behavior is collected by cookies and other technological means, as further described below. This personal information is used to personalize the content displayed on our Services and to improve the content recommendations intended for you.

 

IP addresses and navigation routes. We collect the IP addresses (internet protocol) of all visitors to our Websites and their browsing history, as well as other information such as the pages visited immediately before or after our Websites, the pages requested, the type of browser, the operating system, your internet service provider, the number of times you have visited our Websites and the date and average time you spend on our Websites. We use this information to administer, monitor and improve our Website sand to analyze trends and usage patterns.

 

Cookies and other technologies. Some of our Services may use a technology called “cookies”. A cookie is a tiny element of data that is sent to your device, which may then be stored on your device so we can identify you as an authorized user of our Services. The information recorded by cookies is encrypted and only Croo is in a position to read the content of cookies in order to identify authorized users. You may set your web browser or other device to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from our Services, you may not be able to take advantage of all of the features of our Services.

 

A professional web analysis service. We can also use third parties, including Google, to:

 

* Remarket, which consists of advertising to individuals who have already visited our Websites through other websites including through Google Analytics (internet audience analytics solution); in such a case, relevant third parties, including Google, may advertise our content on sites across the internet;

 

* Use the following features of Google Analytics: the creation of reports based on the saved impressions on Google Display Network (a service that lets you place ads on a variety of news sites, blogs and other niche sites) to attract more potential customers; integration with DoubleClick Campaign Manager (management tool including a set of features used for advertising as well as targeting and monitoring advertising campaigns on websites and mobile devices linked to them, as well as the creation of Google Analytics reports on the demographic data of internet users and their interests); and

 

* Collect, analyze and/or gather your personal information (such as internet users’ IP address, sex, age and interests), as well as create Google Analytics reports on the demographic data of internet users and their interests, in order to help us understand how visitors interact with our website and to improve our products and our websites.

 

The companies conducting remarketing can combine the use of first-party cookies (such as the Google Analytics cookies for example), and third-party cookies (like DoubleClick cookies), to (i) gather personal information; (ii) to inform, optimize and advertise based on your previous visits on our websites; and (iii) to determine the relationship between the registered visits to our websites and the advertising impressions, the other uses of advertising services and the interactions with these advertising impressions and these advertising services. To measure the effectiveness of our ads, these companies may also use tracer tags or web beacons to account for certain information regarding your visits to our websites and to the websites that have links to our site and that advertise it. If so desired, you can deactivate ad personalization and customize the advertisements on the Google Ad Network. Go to https://adssettings.google.com/ to set your preferences.

 

DISCLOSURE OF PERSONAL INFORMATION

 

Principle. Unless specifically stated in this Privacy Policy, we will not disclose, trade, rent, sell or otherwise transfer your personal information, without your consent. Access to your personal information is restricted to Croo, more specifically to their personnel, management, technical, sales and marketing and human resources teams who need access to this personal information as part of their functions for Croo.

 

Exceptions. We may transfer your personal information to:

 

* service providers, i.e., third parties (or otherwise make your personal information available to them) who provide services on our behalf in Canada, in the United States or abroad, including Google in order to use the various Google Analytics features described herein. Our service providers are given the information they need to perform their designated functions, and we do not authorize them to use or disclose personal information for their own marketing or other purposes;

 

* business partners: we may disclose your information to our business partners in order to support our business operations and to allow us to provide our products and services to you. These business partners include companies whose products and services integrate with the Services such as Microsoft Cloud Solutions Provider, Amazon AWS Partner Network, Google Suite and Google Cloud and various SAAS applications. We do not authorize them to use or disclose personal information for their own marketing or other purposes;

 

* to entities, organizations and authorities for legal purposes. In other words, we and our service providers can disclose your personal information in response to a search warrant or other legally valid inquiry or order, or to an investigative body in the case of a breach of an agreement or contravention of law, or as otherwise required or permitted by applicable law. We may also disclose personal information where necessary for the establishment, exercise or defense of legal claims and to prevent actual or suspect loss or harm to persons or property; and/or

 

* to another entity in connection with a merger or sale including all or part of our company or as part of a corporate reorganization or share sale or other change in corporate control. In that case, we may transfer your personal information to a third party as part of the transaction.

 

THIRD PARTY LINKS

 

Our Services may contain links to other sites that Croo does not own or operate. Also, links to our Services may be featured on third party websites on which we advertise. Except as provided herein, we will not provide any of your personal information to these third parties without your consent. We provide links to third party websites as a convenience to the user. These links are not intended as an endorsement of or referral to the linked websites. The linked websites have separate and independent privacy statements, notices and terms of use, which we recommend you read carefully. We do not have any control over such websites, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose, secure and otherwise treat your personal information.

 

SECURITY OF PERSONAL INFORMATION

 

We have implemented, and we apply administrative, technical and physical measures aiming to protect the personal information in our custody and control against unauthorized access, use, modification and disclosure. While we endeavor to protect and keep private such personal information, we cannot guarantee or warrant the security of your personal information against unauthorized disclosure resulting from hardware or software failure or other activities that may compromise the security of your personal information.

 

We have personal information retention processes designed to retain personal information of our customers for no longer than necessary for the purposes stated above or to otherwise meet legal requirements.

 

ACCESS TO YOUR PERSONAL INFORMATION

 

You have the right to access, update, and correct inaccuracies in your personal information in our custody and control, subject to certain exceptions prescribed by law. You may request to access, update, erase, restrict and correct inaccuracies in your personal information that we have in our custody or control by emailing or writing to us at the contact information set out below. We may request certain personal information for the purposes of verifying the identity of any individual seeking access or update to their personal information records.

 

CHANGES TO THE PRIVACY POLICY

 

This Privacy Policy may be updated periodically to reflect changes to the applicable laws or to our personal information practices. The revised Privacy Policy will be posted on our website. We will treat personal information in a manner consistent with the Privacy Policy in effect when we collect your information unless we have your consent to treat it differently.

 

WITHDRAWING YOUR CONSENT TO THE RETENTION, USE AND DISCLOSURE

 

You may withdraw your consent to our retention, use or disclosure of your personal information at any time by contacting us as set out below in the “Contact us section”. However, if you withdraw your consent, we may not be able to provide you with the Services, or to respond to your requests, process your requests or provide you with any help regarding the Services.

 

CONTACT US

 

The Services are offered by The Croo Group Inc., a corporation incorporated under the laws of Quebec, Canada.

 

If you have comments or questions about the way we use your personal information, or if you would like to access, review, update, or correct the personal information in our custody or lodge a complaint regarding our processing of your personal information, please contact us in the manner described below.

 

Attention of: Privacy Officer

Mailing Address: 33 rue Prince, Montreal, Quebec H3C 2M7

E-mail: legal@croo.io

 

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