Softmax Data Inc.

Privacy Policy

 Effective Date: January 1, 2020

We at Softmax Data Inc. (“us,” “our” “we,” or “Company”) consider the protection of your personal information to be a priority. The guidelines contained in this Privacy Statement apply to information collected, used and/or disclosed by us, and describe how we may collect, use and disclose information that we receive as a result of your use of the our products and the Internet-based and mobile applications we may make available to you from time to time on various platforms and devices (collectively, the “Services”).

We reserve the right to modify this Privacy Statement at any time without notice (for example, if we modify our practices regarding the collection or use of information). We will revise our Effective Date to reflect any revisions to this Statement.

Please note that this statement applies to the information you share with us through of connected Services (online, mobile, etc.). This does not apply to information you share with us in “hard copy” – mail, telephone, facsimile, etc. – nor does it apply to information you may share with others through our Services.

Some aspects of our Services may have additional information regarding privacy practices specific to that application, functionality, or service. Please review all information closely as that may change how this general Privacy Statement operates for that specific application, functionality, or service.

What Information May We Collect?

·        We may receive your name, email address, physical address, phone numbers, and other such information as we may request or that you may provide to us from time to time. 

·        We may also collect information that is aggregated in a non-personally identifiable way for our quality assurance purposes and for making improvements to our Services. 

·        We may capture certain information automatically on through the Services, including your Internet protocol address, mobile device identification number, browser type, page access history, linking information, click stream data, page visits, page views, and/or web site log files. 

·        We may use cookies, log files, clear gifs, beacons, and/or similar devices to identify you, to keep track of your interactions with our Services (including those of our partners and affiliates), and to enhance certain activities available on any such Services. These devices are small text or other electronic files that are used for user-identification purposes, record-keeping purposes, and to increase the ease of use of the Services. We may use persistent or not-persistent devices. You can remove or reject persistent devices by following the directions provided in your Internet browser’s “help” file. If you remove a persistent device or reject persistent device, the functionality of our Services, or any part thereof, may be impaired or unavailable. 

How We Define “Personal Information”

As you can see from the above list, not all information we collect is personally identifiable. We defined “personal information” as information that is sufficient to identify you as an individual and contact you personally. This would include your full name, your full mailing address, your telephone number, your personal e-mail address, your user name(s) and password(s). Information that does not enable someone to identify you as an individual and contact you personally is not “personal information” for the purposes of this statement.

What About Children?

It is not our intention to offer the Services to anyone under the age of 13 and will do not actively market to such persons. As such, we do not intentionally collect or maintain information from persons we actually know are under the age of 13. If we learn and are able to confirm to our satisfaction that someone under the age of 13 has shared personal information with us through our Services, we will take steps to delete this information from our databases (if possible) or other measures that are intended to prevent such persons from sharing information with us in the future.

How Might We Use Your Information?

We might use the personal information we collect in the following ways:

·        To contact you with relevant information about our Services, including new products, innovations, opportunities, and offers, whether originating from us or from a third party. 

·        To provide you with personalized offers, promotions, news, events, and other information relevant to your interests or needs. 

·        To establish and maintain customer accounts. 

·        To quickly process your requests for information. 

·        To allow us to respond efficiently to your questions. 

·        To monitor our customer service employees. 

·        To allow us to disclose your information to the extent permitted by law, in the situations described more fully below. 

·        To obtain legal or other professional advice. 

·        To prevent fraud, criminal activity, or harm to users of our Services. 

·        To take any other action as you may request from time to time (for example, certain aspects of our Service may allow you to request that we combine your information with information stored by a third.). 

Any information that is not “personal information” may be used for any reasonable business purpose, as we may engage in from time to time. This would include but is not limited to monitoring Service-related statistics, providing information to third parties in aggregated, non-personally identifiable form, performing analysis of our offerings and business activities, learning more about the demographics of our users, or personal information that has been stripped of all ability to identify you individually (e.g., personal information that has been “hashed” using cryptographic techniques or functionality).

How Do We Protect Your Personal Information?

Although we cannot guarantee the impenetrability of our systems, we have established and implemented reasonable physical, electronic, and administrative procedures to safeguard and secure the personal information we collect online.

Security of your personal information is not only the responsibility of SoftMax, but also of you, the user. Do not share your personal information or other sensitive information (particularly your password(s), credit card numbers, and social security numbers) – except when absolutely necessary, and make sure you know to whom you are giving this information.

Do We Disclose the Information We Collect to Outside Parties?

The following is a list of situations where we may share your information, including (in some cases) your personal information. This list is not exhaustive and is not meant to restrict the uses we may make of the information we collect unless we specifically state otherwise below.

·        We may hire vendors to perform services on our behalf, such as helping us operate our Services, fulfilling user requests, fulfilling a contest or sweepstakes, administering surveys, processing online transactions, executing and optimizing marketing/advertising campaigns, and managing and enhancing consumer data. These companies may require personal and non-personal information to fulfill their task but are only allowed to obtain the personal information that is absolutely necessary for them to accomplish their purpose. Such third parties are prohibited from using the personal information for any other purpose. They have also agreed to keep your personal information confidential and secure. In the case of any network advertiser hired by us (see below), we require the network advertiser to refrain from sharing or using any personal information collected at our request for the benefit of anyone other than us unless we have your explicit consent for that type of use. 

·        We may share your information, including personal information, with our related companies, including our subsidiaries, parent company, equity investors, and affiliated companies. This allows us to get a better understanding of who our consumers are worldwide, improve our Services based on global needs and interests, and market our Services using local resources and based on local interests. 

·        We may hire independent network advertisers to show you banner ads when you visit other, third party Services. To do this more efficiently, the network advertiser may use and place on your computer or connected device certain technologies, such as cookies and/or web beacons, to collect from you non-personal information (in most cases, certain technical and/or browsing data) while you utilize our Services or other applications, functionalities, websites, and services participating in the same network. This information is then used to display advertisements about goods and services (whether offered by us or other companies) more likely to be of interest to you when you visit those other services. If you would like to learn more about this practice or how you can opt out from allowing network advertisers to gather this information from you or use it to provide you tailored ads on other sites, please visit the Network Advertising Initiative (NAI)’s Service. Please note that even if you use the mechanism above to opt-out from this type of information gathering, if, at any time, you disable or delete all cookies stored on your computer, you will have also disabled the same technology (namely, cookies) used by the NAI to help prevent you from receiving this type of advertising. If you do not want this to happen, please make sure not to disable/delete the NAI cookie or add NAI to the approved list of sites from which you allow or accept cookies. 

·        We may wish to generally assess (with the help of a third-party company) how our Services are performing in the marketplace, their popularity or use amongst certain consumer demographics or profiles, and other similar performance metrics. The information disclosed for these purposes will be in aggregate form and limited to demographic or other anonymous data; no personal or login information will be shared except as provided for above. 

·        When we partner with independent, carefully-selected third party companies as part of a jointly-sponsored activity or promotion, or to offer you the ability to receive special offers and discounts directly from third party companies. For example, we may team up with a third-party company to offer a contest, giveaway, or other promotion that promotes both our products and theirs, and as part of such promotion, we may share the collected consumer data (including personal and login information). Similarly, when you sign-up to receive our marketing communications, we may allow you to simultaneously sign-up to receive email offers directly from third party companies who offer other products or services that might interest you. A limited amount of personal information may be shared as part of such third-party email program. 

·        If we are bought or acquired by another company (either fully or partially), merged with another company, or experience a reorganization, bankruptcy, or other similar event, then the information we collect will likely be shared with our successor or assign (i.e., the new company or the company that takes over), subject to the notification procedures set forth in this Statement. 

·        We may be required by law to make certain disclosures, or we may make certain disclosures that are meant to help protect the security and safety of our Services and our users. In such circumstances, we may disclose any information we have collected. We will make this type of disclosure only as permitted or required by law, or when we believe in good faith that it is necessary: (i) to protect your safety or security, including the safety and security of your property; (ii) to protect the security of our Service or third parties’ Services; and/or (iii) to enforce any applicable terms of use, end user license agreement, contest, sweepstakes, promotion, or other rules as may be applicable from time to time. 

Subject to the exclusions identified above, we will not actively share personal information with third party advertisers for their direct marketing purposes unless you give us your consent. Advertisers, however, may obtain public information about you from your profile or other public sources. As to the other kinds of information (i.e., non-personal information such as demographic information, business information, information collected passively, and information received from third party social networking sites), we may use and share this information with third parties consistent with the terms of this Statement.

How Do I Ask Questions and Provide Feedback Regarding Privacy?

We welcome your questions, comments and concerns about privacy. Please contact us at privacy@softmaxdata.com with any questions or comments you may have regarding the privacy of your information.

How Can I Have My Personal Information Deleted?

You may request that we delete the personal information about you that we have collected and stored by sending your request to us in any of the following ways:
By mail:
Suite 1200 – 555 West Hastings Street
Vancouver, BC
V6B 4N6
By e-mail: privacy@softmaxdata.com

Please note that your request to delete personal information is permanent, and we may not be able to recover all information should you wish to in the future. Without complete and accurate personal information, your ability to use our Services may be impacted.

Furthermore, please note that we may not delete personal information collected about you if such information: (a) is required by law to be stored for a certain period of time; (b) is stored as part of a back-up database or similar archive; or (c) is stored as part of a disaster recovery plan (e.g., on mirror databases that are not used except in cases of emergencies). We will not use the personal information stored for any of these reasons for any marketing purpose unless you instruct us otherwise through reregistration for the Services or other such instruction.

Notice to California Residents – Your California Privacy Rights

A business subject to California Civil Code section 1798.83 is required to disclose to its California customers, upon request, the identity of any third parties to whom the business has disclosed personal information within the previous calendar year, along with the type of personal information disclosed, for the third parties’ direct marketing purposes.

If you are a California resident and would like to make such a request, please submit your request in writing to:

Suite 1200 – 555 West Hastings Street
Vancouver, BC
V6B 4N6
Canada

Please note that under California law, businesses are only required to respond to a customer request once during any calendar year.

Effective Date/Changes

This privacy Statement is effective as of the date identified above and applies to all information we collect. We reserve the right to change the Privacy Statement at our sole discretion. Users of our Services will be informed of any such change by posting a new Privacy Statement on the Service and the effective date of any change of Privacy Statement will be clearly marked. Your continued use of our Services after such a change will be deemed consent to the collection and use of information as set forth in the then-current Privacy Statement.