Applifast Inc. (“Applifast”) recognizes the importance of privacy and the sensitivity of personal information. We are committed to protecting any personal information we hold. Thank you for reviewing the Applifast Privacy and Cookie Statement (“Statement”). Applifast Inc. (“Applifast”) is sensitive to the issue of confidentiality in online interactions and are committed to protecting individual privacy across our range of websites, mobile applications, products, solutions, and services (collectively our “Services”).
This Statement applies to visitors and users of Applifast Services that may link to this Statement. Some of our services may adopt different privacy statements, or privacy notices that supplement this Statement, to better fit transactions taking place on those Applifast Services or in accordance with local privacy laws. Any privacy statement or supplementary notice relating to specific Services or a particular transaction will take priority if conflicting with this Statement.
For your convenience, Applifast Services may enable purchases, subscriptions, or use of other products and online services from other entities with different privacy practices, and the personal data collected in those instances will be governed by the respective privacy policies or statements of those other entities.
Your Privacy Rights
The manner in which Applifast handles your personal information is also governed, in part, by various Canadian statutes, including the Personal Information Protection and Electronic Documents Act, and the Canadian Standards Association Model Code for the Protection of Personal Information, which it incorporates. The Act gives you rights concerning the privacy of your personal information.
Why Does Applifast Need Personal Information?
Applifast provides legal services and products to a wide range of clients. In doing so, it collects personal information to provide those clients with legal services, information (including materials concerning its services and developments in the law). In addition, some personal information relating to your financial affairs is required to comply with client identification and verification rules set out by the Law Society of Manitoba.
What personal information do we collect?
Personal information is any information that identifies you, or by which your identity could be deduced. If we did not collect and use your personal information, we could not provide you with the Services in many cases.
Applifast Services collect personal information from and about individuals for a variety of purposes. In some cases, Applifast requests personal information from you, or from your employer in the case of organizational Services. In other cases, we obtain personal information by noting how you and the devices you use interact with our Services. Examples of personal information include:
• first and last names
• job titles or roles
• phone numbers
• e-mail addresses
• shipping and billing addresses
• login credentials
• passport or government identification information
• date of birth
• country of residence
• web statistics and use
How do we collect your personal information?
We collect information only by lawful and fair means, and not in an unreasonably intrusive way. Wherever possible we collect your personal information directly from you, both at the start of any engagement of Applifast to provide Services and in the course of providing the Services. Sometimes we may obtain information about you from other sources, for example:
• you choosing to follow Applifast on social media sites;
• data from third-party sources that are either publicly or commercially available. This information includes personal data such as your name, address, email address, preferences, interests, and demographic data. We combine personal information collected through our Services with other information that we or third parties collect about you in other contexts, such as our communications with you via email or phone, or your customer service records. We treat such combined information as personal information and protect it in accordance with this Statement.;
• from a government agency or registry (including Canada Revenue Agency);
• from automatic collection sources, including cookies and tracers; and
• from responses to LinkedIN advertisements or questionnaires.
Cookies and tracers
Applifast may use, and may permit service providers to use, tracking scripts or “tracers” and web beacons that recognize a unique identifier from a cookie placed on your device by another website. For example, we may use a tracer to determine whether you visit our pages after visiting a site where we placed a banner ad. We also use these technologies to compile information about your website usage and your interaction with email or other communications, to measure performance, and to provide content and ads that are more relevant to you. A web beacon is typically a transparent graphic image that can be embedded in online content, videos, and emails, and can allow a server to read certain types of information from your device, know when you have viewed the beacon, and the IP address of your device. For example, we include web beacons in our promotional email messages or newsletters to determine whether our messages have been opened or interacted with and whether our mailing tools are working properly.
In most cases, we shall ask you to specifically consent, if we collect, use, or disclose your personal information. Normally, we ask for your consent in writing, but in some circumstances, we may accept your oral consent. Sometimes, your consent may be implied through your conduct with us.
Use of Your Information
We use your personal information to provide legal advice and services to you (including verification of any potential or actual conflicts of interest), to administer our client (time and billing databases) and to include you in any direct marketing activities, as well as any use required to meet professional or legal responsibilities. If you tell us that you no longer wish to receive information about our services, or about new developments in the law, we will not send any further material.
Applifast does not disclose your personal information to any third party to enable them to market their products and services.
Disclosure of your Personal Information
Certain Services must disclose information to third parties assisting us in processing a transaction requested by you (e.g., credit card service providers). In addition, Applifast hires service providers to perform work on its behalf. Any such service providers will be permitted to obtain data from the Services only to deliver the services Applifast has retained them to provide and will be prohibited from using data for any other purpose. Applifast discloses personal information to these service providers for the purposes identified in this Statement and for the purposes for which you have engaged Applifast or provided your personal information to Applifast, including to send promotional communications to you via email, postal mail, fax, SMS and phone as permitted by local law and subject to your contact preferences. In order to cooperate with legitimate governmental requests, subpoenas, or court orders, to protect Applifast and/or Applifast’s systems and customers, to establish, protect, or exercise our legal rights or defend against legal claims, or to ensure the integrity and operation of Applifast and/or Applifast business and systems, Applifast accesses and discloses the necessary and appropriate information under the circumstances.
Under certain circumstances, Applifast will disclose your personal information:
• when we are required or authorized by law to do so, for example if a court issues a subpoena;
• when you have consented to the disclosure;
• when the Services we are providing to you requires us give your information to third parties your consent will be implied, unless you tell us otherwise;
• where it is necessary to establish or collect fees;
• if we retain other entities or subsidiaries at your request, and on your behalf;
• if the information is Publicly Available Personal Information, as it is defined under the Personal Information Protection and Electronic Documents Act.
Updating Your Information
Since we use your personal information to provide legal services to you, it is important that the information be accurate and up-to-date. If during the course of the retainer, any of your information changes, please inform us so that we can make any necessary changes.
How is my information stored?
Your personal information is stored both physically and electronically. Applifast stores your personal information for as long as you use the Services, and no longer than is necessary for the purposes for which the information was collected, or for which it is legitimately further processed. Thereafter, Applifast retains personal information for a period of time set forth in its corporate retention schedules. In the case of organizational Services data, Applifast retains personal information according to the timeframes set forth in relevant customer agreements, or in lieu of an agreement, for as long as a legitimate business purpose exists.
Is My Personal Information Secure?
Applifast takes all reasonable precautions to ensure that your personal information is kept safe from loss, unauthorized access, modification or disclosure. Among the steps taken to protect your information are:
• premises security;
• restricted file access to personal information;
• deploying technological safeguards like dual-factor authentication for email access, security software and firewalls to prevent hacking or unauthorized computer access;
• internal password and security policies.
Access to Your Personal Information
You may ask for access to any personal information we hold about you.
Summary information is available on request. More detailed requests which require archive or other retrieval costs may be subject to our normal professional and disbursement fees.
If Applifast holds information about you and you can establish that it is not accurate, complete and up-to-date, Applifast will take reasonable steps to correct it.
Can I be denied access to my Personal Information?
Your rights to access your personal information are not absolute. We may deny access when:
• it is required or authorized by law (for example, when a record containing personal information about you is protected by solicitor-client privilege);
• to do so would reveal confidential commercial information, and the personal information cannot be severed from the record;
• to do so could reasonably be expected to threaten the life or security of another individual, and the personal information cannot be severed from the record; or
• the information was generated in the course of a formal dispute resolution process.
If we deny your request for access to, or refuse a request to correct information, we shall explain why. Applifast does not use your Social Insurance Number as a way of identifying or organizing the information we hold upon you, although your Social Insurance Number may be collected by us if required by your legal matter.
Can I request anonymity?
Whenever it is legal and practicable, we may offer the opportunity to deal with general inquiries without providing your name (for example, by accessing general information on our website). However, if you retain our office to provide legal services to you, we are required to confirm the identity of all new clients. It may also require us disclose information to FINTRAC or other regulatory bodies in relation to certain large cash transactions.
Communicating with Us
You should be aware that e-mail is not a 100% secure medium, and you should be aware of this when contacting us to send personal or confidential information.
Requests for Access
If you have any questions, or wish to access your personal information, please write to our Privacy Contact at:
Attn: Privacy Officer
251 Cree Crescent
If you are not satisfied with our response, the Privacy Commissioner of Canada can be reached at:
112 Kent Street,
Ottawa Ontario, K1A 1H3
If you apply to Applifast for a job, we need to consider your personal information, as part of our review process. We normally retain information from candidates after a decision has been made, unless you ask us not to retain the information. If we offer you a job, which you accept, the information will be retained in accordance with our privacy procedures for employee records.