Hello, we are Discrete Data Inc. (“Discrete Data” or “We”)!
Your privacy is important to you, and it is important to us. We feel that mutual trust is vital in developing and maintaining relationships with our clients. In this policy, we will attempt to clarify the ways in which your personal data comes to us, what we do with it, and those rare occasions when we must disclose it.
The overarching theme of this policy can be summarized by our business model: We would like you to pay for using our software. We have no interest in monetizing our interactions with you.
This seems like a good opportunity to discuss the “software for nothing” trend. There is a lot of great free software created to support a cause or for the sheer joy of the creative process. We commend these developers for their dedication and enthusiasm. However, we recommend that you ask one question of all free software: What do they get out of it? If the answer is unclear, then ask a second question: What is their business model?
With all that said, let’s continue.
When does this policy apply?
This privacy policy applies when you use our mobile apps (‘Apps’) and when you access our website (www.discretedata.ca). If you are reading this, you are probably accessing our website.
This policy also applies when we are in communication via email or on social media platforms.
If you leave our website to go to the website of a third party, this privacy policy does not apply. You should consult the privacy policies of those parties to determine how they use your data.
Our Apps and website can be accessed and used from everywhere in the world. The laws that apply to the protection of your personal data may vary depending on where you are located. Discrete Data strives to comply with all applicable laws – if you have questions based on your situation, feel free to contact us engage@discretedata.ca.
Personal Data
Our definition of personal data is any information that allows us to identify you using either direct or indirect means.
Email
If you choose to contact us via email, we will have access to your email address and other information potentially provided by you in that email. This might include your name, the email subject, the message body and any files that you attach to that email. We will use this information to determine what action (if any) is required and to create an email response to you. We do not use your email address to perform any mass-marketing.
Cookies
Cookies are pieces of data that a websites use to hold information. They are often stored locally on your device when you use a web browser to view a website. We use cookies to track whether or not you accept the use of cookies (yes, we understand that seems strange). We do not respond to "Do Not Track" browser settings, but if this capability is added in the future we will update this privacy policy to reflect the change. To prevent cookies from being stored on your device, please see the documentation for your web browser about blocking cookies. However, doing so might impact your use of our website (e.g. you might be constantly asked to accept the use of cookies, since that setting is stored in a cookie).
Website Logs
Our web host logs information about requests made to read our web pages. These logs are intended to be used to troubleshoot issues with the Site. However, they may contain personal data such as the IP address of your device, the IP address of your internet service provider, the date and time that you requested the page, the browser or app that you used to access the page, and potentially the website containing the link you followed to access the page.
Social Media
If you interact with our accounts/pages via a social media platform, we will be able to view personal data that you make available via your privacy settings on that platform.
Data Retention
Your personal data is kept until it is no longer required to for its specified use or as required by law (whichever is longer). Data is stored in both Canada and the United States.
Other Data
Subscriptions: Some of our Apps use auto-renewable subscriptions processed by Apple's App Store. We determine if your subscription is valid using a means that follows Apple's guidance for auto-renewable subscriptions. We track the status of your subscription using an anonymized value called the original transaction identifier. Only Apple has the means to determine the App Store user to which an original transaction identifier refers, and they do not share this information with us. For more details, please read Apple's Auto-renewable Subscriptions articles.
App Analytics: Apple can collect App Analytics data from our apps when a user has agreed to submit analytics data from their devices. This gives us non-personal, aggregated data to indicate how users find our apps (e.g. from our website), how many active users we have, how many users delete our apps, etc. We use this data to assess the impact of marketing efforts and user retention initiatives. For more details, please read Apple's Gain Insights with Analytics article.
Protecting Your Information
The security of your personal data is important to us. We use appropriate safeguards and security measures to protect your personal data from unauthorized access, disclosure, or misuse.
Although we cannot take responsibility for any theft, misuse, unauthorized disclosure, loss, alteration or destruction of data by a third party, we take reasonable precautions to prevent such unfortunate occurrences.
Disclosure of Information
We do not sell your personal data. However, we may be required to share your information with third parties acting on our behalf or as permitted or required by law:
- To a government institution or other person or entity that has asserted its lawful authority to obtain the information
- Where we have reasonable grounds to believe the information could be useful in the investigation of unlawful activity
- To comply with a subpoena or warrant or an order made by a court, person or entity with jurisdiction to compel the production of information
- To comply with court rules regarding the production of records and information
- To our legal counsel
Exercising Your Rights
We respect your rights to your data. The rights that apply to you will depend on your situation and the specific request in question. The following represents some of the rights to which you might be entitled:
- The right of access
- The right to rectification
- The right to erasure
- The right to restrict processing
- The right to data portability
- The right to object
- Rights related to automated decision making including profiling
We will do our best to accommodate your requests, and do so without additional charge. If the specific request requires substantial effort, we might have to cover our costs by charging a reasonable fee to process the request subject to applicable laws. We will contact you in the event that such measures apply to your request.
If we must deny your request, you will be notified in writing with the rationale behind the decision. Your relevant personal data in question will be kept until the matter is resolved. We will respond to your request within thirty (30) days, unless other arrangements have been made.
To remove your consent to electronic communications from us, please contact us via email at engage@discretedata.ca.
Changes to this Privacy Policy
We will update this privacy policy in response to new legal requirements or to reflect changes in our practices. New Apps or changes to App behaviour or our website might also require changes to our privacy policy. Notification of such changes will be noted in the description of updates to our Apps, and this web page can always be accessed to review this policy.
Last updated: March 26, 2020