Last Revised: September, 2018
Introduction
At Crestline, we recognize the importance of your privacy and take it very seriously. This Privacy Policy describes how we collect, use and process your information when you use our Services. All of the forms of data, content and information described below are collectively referred to as “information.” By using our Services, you confirm that have read, understood and agreed to be legally bound by the provisions of this Privacy Policy and our Terms of Use.
Application and Scope
This Privacy Policy applies to any personal information (as defined below in the section entitled “Definition of Personal Information”) collected or generated by Crestline. Individuals, about whom personal information is collected by Crestline, are protected by the rights and safeguards contained in this Privacy Policy.
As Crestline provides products and services to commercial customers, it only receives and processes limited amounts of personal information. When our customers use Crestline information technology services, this may involve our customers processing personal information for which they are the data controller. Neither we nor our affiliates determine the types of personal information our customers store on our servers, or which is otherwise processed in connection with the services we provide. Our customers are responsible for compliance with any relevant data protection laws. All decisions on the processing of the personal information are made entirely at the discretion of the customer, and Crestline defines its obligations in relation to such personal information in its agreements with its customers. The personal information that our customers process using our services is not within the scope of this Privacy Policy (this information would be subject to these customers’ privacy policies), although we are committed to protecting this information through the security systems and controls we have put in place.
Definition of Personal Information
For the purposes of this policy, personal information means any information about an identifiable individual. Depending on the jurisdiction in which we operate, this may include, for example, contact details you have given in connection with an account with us, or such other information you have given us to receive information about or use our services. Personal information that is aggregated and cannot be associated with an identifiable individual is not considered to be your personal information.
Collection and Use of Personal Information
Crestline will not collect or use personal information for any other or new purpose without obtaining consent, unless required or authorized by law.
With your consent and for the purposes outlined below, we collect most of our information about you directly from you, with. We may also obtain personal information about you from third parties, with your consent.
We use the information you provide to provide you with the Services; to communicate with you; to operate, maintain, and enhance the Services; and to fulfill your specific requests.
Crestline collects personal information, when you register for our services, to establish, develop and preserve our business relationships. In order to establish and administer your account, to provide services, and to respond to inquiries, we will collect your name, address, phone number(s) and email address, as well as other account and payment information, including information pertaining to your use of our products and services. We will also use personal information to establish or verify the eligibility and credit of persons that use, or intend to use, one or more of the products or services offered by Crestline.
We collect personal information for quality assurance purposes, and to manage our businesses and ensure security of our systems and networks.
Furthermore, Crestline may also use the information that we collect from you to:
- Provide, operate, maintain and improve the Services;
- Enable you to access and use the Services, including uploading, downloading, collaborating on and sharing content and sending emails on your behalf;
- Send you technical notices, updates, security alerts and support and administrative messages;
- Provide and deliver the services and features you request, process and complete transactions, and send you related information, including purchase confirmations and invoices;
- Respond to your comments, questions, and requests and provide customer service and support;
- Communicate with you about services, features, surveys, newsletters, offers, promotions, contests and events, and provide other news or information about us and our select partners;
- Monitor and analyze trends, usage, and activities in connection with the Services and for marketing or advertising purposes;
- Investigate and prevent fraudulent transactions, unauthorized access to the Services, and other illegal activities;
- Personalize and improve the Services, and provide content, features, and/or advertisements that match your interests and preferences or otherwise customize your experience on the Services;
- Link or combine with other information we receive from third parties to help understand your needs and provide you with better service;
- Enable you to communicate, collaborate, and share files with users you designate;
- For other purposes about which we notify you.
Your Consent
By purchasing our services you are providing your consent to the collection, use and disclosure of personal information as set out in this Privacy Policy. In certain circumstances, Crestline obtains consent from the individuals concerned for the collection, use or disclosure of personal information through various means: orally or through written documents, including agreements, forms or other printed or electronic communications.
In exceptional circumstances personal information may be collected, used or disclosed without consent which may include (i) where it is clearly in the interest of the individual and consent cannot be obtained in a timely way, such as in emergencies, where the life, health or safety of the individual is threatened, or where legal, medical or security reasons make it impossible or impractical to obtain consent; (ii) when information is being collected, used or shared for the detection, prevention of or remediation to, the breach of an agreement, fraud or other illegal activity, and the collection of consent might defeat the purpose of collecting the information; (iii) to collect a debt; or (iv) to comply with a subpoena, warrant or other court order, or as may be otherwise required or authorized by law or by any regulatory bodies having jurisdiction
Withdrawing your consent
You may withdraw your consent at any time on reasonable notice and subject to any legal or contractual restrictions. Without such consent, Crestline may limit the services or products it provides you.
To opt-out of commercial emails, simply click the link labeled “unsubscribe” or “opt-out” at the bottom of any commercial electronic communication we send you. Please note that even if you opt-out of promotional communications, we may still need to contact you with important information about your account
You may decide that you prefer Crestline not to use your personal information to promote new and/or additional products and services which may be of interest to you and refuse that we contact you by mail or telephone for marketing or quality control purposes. If this is the case, you may advise us by contacting customer service or contacting us using the information detailed in the How to Contact Us section below.
Sharing of Personal Information with Third Parties
To fulfill the purposes set out in this Privacy Policy, your personal information may be made available by Crestline to third-parties or service providers. Crestline will NOT sell, rent or trade your personal information to any third party. Only those employees of Crestline or trusted third party contractors, who need access for business reasons, or whose duties reasonably so require, will be granted access to personal information.
Crestline may use third party service providers to perform services on our behalf, for example, the purposes of customer credit verification and installation of services. We only provide them with the strict necessary amount of information in order for them to provide the services required to carry out the services you require from us. Crestline will endeavour to put in place contractual agreements requiring that those third parties adhere to confidentiality and security procedures and protections that are, at a minimum, equivalent to those employed by Crestline itself.
In connection with a sale or transfer of business or assets, an amalgamation, re-organization or financing of parts of our business, we may disclose personal information to a third party. However, in the event the transaction is completed, your personal information will remain protected by applicable privacy laws. In the event the transaction is not completed, we will require the other party not to use or disclose your personal information in any manner whatsoever and to completely delete such information.
Information may also be disclosed to our accountants, auditors, agents and lawyers in connection with the enforcement or protection of our legal rights.
Cross-border Transfer of Personal Information
Crestline may transfer certain personal information across geographical borders to other Crestline facilities. Crestline may also store personal information in a jurisdiction other than where you are based and such jurisdiction may not provide the same level of protection for your personal information as your home country. By providing your information to Crestline, you are consenting to this transfer and/or storage of your information across borders. Each Crestline location is required to safeguard personal data in accordance with its contractual obligations and data protection legislation applicable to its provision of services. Your personal information will only be transferred if appropriate or suitable safeguards are in place.
Crestline may receive personal information from its affiliate entities located in the European Union in order to assist those affiliates in providing services and conducting their business operations. Where Crestline receives personal information in this manner, it acts as a processor under data protection laws, and the relevant affiliate located in the European Union is deemed to act as the data controller, in accordance with EU data protection laws. For the avoidance of doubt, this does not include personal information uploaded to our systems by the customers of our affiliates in the European Union in respect of which those customers are considered to be the data controllers.[AK1]
Disclosure of Personal Information as Permitted or Required by Law
Your privacy is very important to us. We do not sell or disclose your personal information to third parties except as provided in this Privacy Policy. Your information may be disclosed to third parties only in the following circumstances:
- We may disclose your personal information if required to do so by law or subpoena.
- We may disclose your information if we believe that such action is necessary to: (a) protect and defend our rights and property, our Services and/or users of our Services; (b) enforce the terms of use with respect to our Services (including investigation of potential violations thereof); (c) detect, prevent or otherwise address fraud, security or technical issues; or (d) protect the safety of users of the Services, us or third parties. These third parties may have access to your personal information only for purposes of performing these tasks on our behalf and under obligations similar to those in this Privacy Policy.
- We may share non-personally identifiable with third parties with whom we work who help us deliver promotions, offers and ads, and to improve the relevancy such promotions, offers and ads.
- We may use certain trusted third party companies and individuals to help us provide, beta test, analyze, and improve the Services. These third parties may have access to your personal information only for purposes of performing these tasks on our behalf and under obligations similar to those in this Privacy Policy.
Security of Personal Information
Your personal information is protected for your privacy and security. We safeguard the security and confidentiality of the data you send us with physical, technical, and managerial procedures. Please be aware that, despite out best efforts, no security measures are perfect or impenetrable. While we strive to protect your personal information, we cannot ensure the security of the information you transmit to us.
Retention
Personal information will be retained only as long as necessary for the fulfilment of the purposes for which it was collected and for which consent was received, unless otherwise required by law. Personal information that is no longer required to fulfil the identified purposes will be destroyed, erased or made anonymous. Crestline has developed and implemented detailed retention principles, and will ensure destruction of personal information in a method that prevents improper access.
Access and Correction
Crestline respects your right to access and correct your personal information. If you have submitted personal information to Crestline, under most circumstances you have the right to reasonable access to that data to correct any inaccuracies. You can also make a request to update or remove information about you and we will make all reasonable and practical efforts to comply with your request, so long as it is consistent with applicable law and professional standards.
If you need assistance updating your personal information, please contact us using the contact information detailed in the How to Contact Us section below.
Notice to the Data Subjects of Our Customers
If you have provided personal information to our customers, or to customers of Crestline affiliates, who are using Crestline’s information technology services to store or otherwise process your personal information, all such personal information on our systems is provided and controlled by our customers who are the data controllers under applicable data protection law. Crestline will not process that personal information except as provided for in the agreement between us (or our affiliate) and the customer. The customers remain responsible for the personal information they collect and process, and are not discharged of their obligations to comply with applicable data protection laws.
Crestline has no direct relationship with the individuals whose personal information is processed by our customers. If your personal information is on our systems as a result of you having provided it to one of our customers and would no longer like to be contacted by that customer, or you wish to exercise any other data protection rights, please contact that customer directly.
If you would like more information on how your personal information will be processed and protected, as well as your rights in relation to that personal information, please refer to the privacy policy of the customer to which you provided your personal information. If you ask us to delete your personal information, we will tell our customer about this request.
How to Contact Us
If you have questions, concerns or complaints regarding this Privacy Policy or the personal information that Crestline has about you, please contact:
Perry Stathopoulos, Privacy Officer Crestline
203-15260 Yonge St.
Aurora, ON
L4G 1N4
By e-mail: perry [@] crestline.net
Change to our Privacy Policy
We reserve the right, at our sole discretion, to modify this Privacy Policy at any time. If we modify this Privacy Policy, we will post the modification on the website and/or provide you with notice of the modification. We will also update the date at the top of this Privacy Policy. By continuing to access or use the Services after we have posted such a modification or have provided you with notice of a modification, you are indicating that you agree to be bound by the modified Privacy Policy. If the modified Privacy Policy is not acceptable to you, your only recourse is to cease using the Services.