DashThis

Moment Zéro Inc., d.b.a. DashThis (“DashThis”) takes your privacy very seriously and is committed to protecting it by complying with this Privacy Policy (the “Policy”).

DashThis has made sure to inform its employees, subcontractors, and agents that they must comply with this Policy if they have access to Personal Information while performing their duties.

PERSONAL INFORMATION

The term "Personal Information" refers to information that can be used to, directly or indirectly, identify an individual. This excludes business contact information, except where privacy laws deem such information to be Personal Information.

Anonymized data is not Personal Information.

SCOPE AND APPLICATION

This Policy applies to DashThis' customers, as well as any end user who uses or accesses the Platform (collectively, the "Client"). It also applies to Client’s Personal Information that has been entrusted to DashThis for the purpose of providing contracted services, including Client’s Personal Information in the possession of DashThis' service providers.

POLICY’S CONTENT

• How DashThis collects, uses, discloses, destroys, and protects its Clients’ Personal Information.
• The types of information DashThis may collect when a Client visits its Website available at DashThis.com or uses the DashThis Reporting Dashboards App available at dashthis.com/app (collectively, the “Platform”).
• DashThis’ practices regarding Personal Information collection, use, protection, conservation, and disclosure.

PRIVACY PRACTICES

To ensure the protection of the Personal Information it possesses, DashThis has established and implemented policies and practices governing the management of its Personal Information.

These internal policies and procedures govern the collection, use, communication, conservation, and destruction of Personal Information, as well as the handling of complaints, information security and data governance. These policies and practices also provide a framework for the operationalization of privacy impact assessments, as well as for the prevention of and response to potential privacy incidents.

PRIVACY OFFICER

DashThis has appointed a Privacy Officer who is responsible for ensuring that DashThis complies with its internal protection of Personal Information practices. The Privacy Officer provides support in the event of any questions, complaints or requests relating to the protection of Personal Information.

To contact the Privacy Officer, please use [email protected].

COLLECTION

Personal Information. DashThis may collect Personal Information when a Client accesses and uses the Platform. Personal Information collected may include, but is not limited to: name, civic address, phone number, e-mail address, IP address, language preferences, location of connection (country), and online behavior. Some Personal Information is solely collected when Client activates the Access Log feature available on the Platform.

Non-personal Information. DashThis may collect information that does not directly or indirectly reveal your identity or directly relate to an identifiable individual, such as demographic information, or statistical or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal information. For example, we may aggregate Personal Information to calculate the percentage of users accessing a specific Platform feature.

Technical Information. DashThis may collect technical information, including your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, or information about your internet connection, the equipment you use to access our Platform, and usage details.

Non-Personal Details About Your Platform Interactions. These include the full Uniform Resource Locators (URLs), clickstream to, through and from our Platform (including date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, or any phone number used to call our customer service number.

How We Collect Information. Personal Information is collected in the following ways:

• Direct interactions with Client, when the latter provides DashThis with the information (for example, by filling in the fields available on the Platform).
• Automated technologies when accessing the Platform, through the use of cookies and similar technologies.

USE

DashThis collects and uses Personal Information for the following purposes:

• Establishing and maintaining a commercial relationship with its Clients, including sending electronic marketing communications (e-mails or text messages). You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any communication DashThis sends.
• Developing, improving, promoting, or providing products and services to its Clients, including the diagnosis of technical problems or the improvement of the functionalities and security of the Platform.
• Anonymizing Personal Information.
• Meeting contractual or legal obligations.
• Investigating and resolving incidents.
• Any other purpose permitted by law, including responding to law enforcement or governmental requests.

COMMUNICATION AND TRANSFERS

DashThis will not intentionally grant any third-party access to Personal Information, except to the extent that such disclosure is permitted or required by law.

DashThis may, from time to time, communicate certain Personal Information to subcontractors or agents in order to provide services and make available all functionalities offered on the Platform (for example, support services, maintenance, development, legal representation, etc.). These third parties will only have access to Personal Information that is necessary to perform their tasks and are required not to disclose or use it for any other purpose.

Please note that these subcontractors or agents may be located in Canada or in other jurisdictions. Please be aware that DashThis has contractual agreements with these subcontractors to ensure the security of the data entrusted to them and that DashThis performs Privacy Impact Assessments before disclosing any Personal Information outside the province of Quebec. Although Personal Information transmitted is protected by appropriate security measures, Personal Information may be made available to foreign government agencies, pursuant to applicable laws.

INTEGRATION API

When authorizing any of the integrations offered within the Platform, our code will have access to any Personal Information made available by the integrations API. If the integration requires a specific set of permission scopes to be authorized by the user, the API data accessed will also be limited to these scopes.

Data retrieved from certain integrations may be cached for a short period and may be stored on DashThis’ servers to improve the deliverability of data with the service.

Data obtained from integrations will only be used in the dashboard and reports that the Client has access to. No Personal Information is used internally or in any place that Client does not have access to.

Collection and use of Personal Information through integration API is subject to third-party privacy policies and terms of use.

RETENTION

DashThis has established retention periods for Personal Information under its control. DashThis will not retain Personal Information longer than is necessary or relevant for the identified purposes, unless otherwise required by law or regulation. Once these periods have expired, DashThis will destroy the Personal Information in accordance with its internal Personal Information management policies. As a general rule, DashThis destroys all Personal Information regarding cancelled accounts, within a reasonable timeframe following such cancellation.

Any individual may request that his or her Personal Information be rectified or deleted by contacting the Privacy Officer.

SECURITY

DashThis makes the security of the Personal Information it collects, uses, and controls a priority. Accordingly, DashThis ensures that security measures appropriate to the sensitivity of the data are in place to protect Personal Information against such risks as loss or theft, unauthorized access, disclosure, copying, use, modification, or destruction.

To the extent possible and applicable, DashThis implements, maintains, and monitors technical and administrative measures to help protect the security, integrity, availability, and confidentiality of the Personal Information it collects or over which it has control.

DashThis' Personal Information management program includes incident detection and response practices and procedures designed to facilitate the prompt reporting of incidents involving Personal Information.

GDPR

DashThis is deeply committed to protecting the privacy and security of personal data in accordance with GDPR principles. As a data processor, we work closely with our clients, who act as data controllers, to ensure that personal data is handled responsibly and securely. We have implemented robust technical and organizational measures to support our clients in meeting their GDPR obligations, including assisting with individual rights requests, ensuring secure data transfers, and promptly notifying clients in the event of a data breach.

Additionally, DashThis processes and stores data in Canada, which has been recognized by the European Commission as providing an adequate level of data protection under GDPR, or with well-knowed cloud services providers that provides adequate levels of protection. We also ensure that any subprocessors we engage meet strict data protection standards.

Our privacy practices are designed to align with high standards, and we continuously review and enhance our processes to meet evolving regulatory requirements. If you have any specific questions or concerns, our Privacy Officer is available to provide further details and reassurance at [email protected].

COOKIES

DashThis uses cookies and similar technologies that have two main uses:

1. Connection, performance, and functionality cookies: These cookies help to personalize and improve the user experience. For instance, they may remember your preferences so you don't have to re-enter information more than once, or they may remember your login information, so you don't have to re-enter it each time you use the Platform. They allow DashThis to understand your behavior in order to improve our services and the Platform.
2. Security cookies: These cookies help protect your accounts from unauthorized users. They help maintain session integrity and provide increased security by blocking unauthorized attempts to access your account.

DashThis uses two main types of cookies:

1. Session cookie: This cookie is stored for the duration of your visit on the Platform, after which it is deleted from your device. It identifies you and is deleted when you leave the Platform.
2. Persistent cookies: This cookie is stored on your device until it expires and will be retrieved on your next visit.

Please note that the use of cookies only identifies you as a user and does not otherwise recognize you.

Disabling Cookies

You can prevent the Platform's personalization features by disabling cookies on your browser. You can do this by changing the settings on your browser or mobile device.

However, if you decide to refuse cookies, some pages or sections of the Platform may not display correctly, or some features may not be available.

POLICY CHANGES AND UPDATES

DashThis may, at its discretion, update, revise, modify or supplement this Policy from time to time. If a material change is made to the Policy, DashThis will send you a link to the new version of the Policy and a notice will be posted on the Policy's publication page. DashThis asks its users to review the revised Policy before continuing to use its services.

Continued use of the services provided by DashThis after the revised Policy becomes effective constitutes consent to the revised Policy.

EUROPEAN UNION PRIVACY RIGHTS

This Section applies only to Personal Information that is collected or processed on an individual located in the territory of the European Union at the time of such collection.

We inform you that your Personal Information will be transferred to and processed in Canada, which has different privacy laws than those in your country of origin. Canada has received an adequacy decision from the European Commission on the basis of article 45 of Regulation (EU) 2016/679 whether a country outside the EU offers an adequate level of data protection.

If you believe we are processing your personal data in violation of the law, you have the right to lodge a complaint with the Data Protection Authority in your country. You may also have the right to make a GDPR complaint to the relevant Data Protection Authority, a list of which is available at EDPB – The European Data Protection Board website.

CONTACT US

Our Privacy Officer is available to respond to any questions, requests or complaints regarding DashThis's privacy practices. Here is his contact information:

Privacy Officer

Moment Zéro Inc. d.b.a. DashThis

1255 Bd Lebourgneuf #550

Québec City (Québec) Canada

G2K 0M6

By email: [email protected]

DashThis is committed to responding promptly and accurately to all your questions and concerns about the privacy and security of Personal Information, as well as our privacy policies and practices.