Last Updated: August 10, 2020
Information We Collect
- Personal Information
Personal Information is any information recorded in any form that identifies or can identify an individual and includes any information provided to us by you in using our Site or Services. Personal Information that we collect includes, but is not limited to:
- Contact Information: information that you may provide us for inquiries or other matters, such as your name, e-mail address and telephone number.
- Usage information: We collect usage information about you whenever you interact with our Sites and Services. This includes which webpages you visit, what you click on, when you perform those actions, and your language preference.
- Device and browser data: We collect information from the device and application you use to access our services. Device data mainly means your IP address, operating system version, device type, system and performance information, and browser type. If you are on a mobile device, we also collect the UUID for that device.
- Information from page tags: We use third party tracking services that employ cookies and page tags to collect data about visitors to our websites. This data includes usage and User statistics. Emails sent by UNMARRY.CA or by Users through our services include page tags that allow the sender to collect information about who opened those emails and clicked on links in them. We provide more information on cookies below.
- Log Data: our web servers keep log files that record data each time a device accesses those servers. The log files contain data about the nature of each access, including originating IP addresses, internet service providers, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system versions, device type and timestamps.
If you are a customer, we will also collect:
- Registration information: You need to create account before you can use the Services. When you register for an account, we collect your first and last name, username, password and email address.
- Service Information: information that you provide us in using our Services. This includes personal information that you may input in our guided interview and document builder tools that are stored on our Site.
- Billing information: if you make a payment to UNMARRY.CA, we require you to provide your billing details, a name, address, email address and financial information corresponding to your selected method of payment (e.g. a credit card number and expiration date or a bank account number).
- Account settings: You can set various preferences and personal details on our customer setting pages. For example, your default language, time zone and communication preferences (e.g. opting in or out of receiving marketing communications from UNMARRY.CA).
We receive Personal Information about you from other sources. For example, we will receive information from credit card processors regarding whether the credit card details you gave us have been accepted or declined.
- Non-Personally Identifiable Information
Personal Information does not include information that is aggregated or anonymized in such a manner that it cannot be connected to you or any User. This may include geographic location such as province or country, page views, and date and time range of your interaction with the Site. Such information by itself or together cannot be tracked to a specific individual’s personally identifiable information.
To better understand this policy, UNMARRY.CA has set out some basic definitions to use when reading and interpreting it.
- Collection:the act of gathering, acquiring, recording, or obtaining Personal Information from any source, including third parties, by any means.
- Consent:voluntary agreement to the collection, use and disclosure of Personal Information for defined purposes. Consent can be either express or implied and can be provided directly by the individual or by an authorized representative. Express consent can be given orally, electronically or in writing, but is always unequivocal and does not require any inference on the part of UNMARRY.CA. Implied consent is consent that can reasonably be inferred from the circumstances or from an individual’s action or inaction.
- Disclosure:making Personal Information available to a third party for that party’s own use.
- Mediation Services: means the videoconference mediation services that UNMARRY.CA will provide to you through our Site.
- Mediators: means our mediators that provide Users with the Mediation Services.
- Personal Information:information about an identifiable individual that is recorded in any form, but does not include aggregated information or depersonalized that cannot be associated with a User (“Non-Personally Identifiable Information”).
- Transfer: making Personal Information available to a third party for processing, storage or otherwise, solely to be used on behalf of UNMARRY.CA.
- Use:the treatment, handling and management of Personal Information by and within UNMARRY.CA.
Principle #1 - Accountability
UNMARRY.CA shall make known, upon request, the title of the person or persons designated to oversee UNMARRY.CA's compliance with this policy.
UNMARRY.CA is responsible for Personal Information in its possession or custody, including information that has been transferred to a third party for processing. UNMARRY.CA shall use contractual or other means to provide a comparable level of protection while the information is being processed by a third party.
UNMARRY.CA shall implement policies and practices to give effect to these principles, including:
- Implementing procedures to protect Personal Information;
- Establishing procedures to receive and respond to complaints and inquiries;
- Training staff and communicating to staff information about the organization’s policies and practices; and
- Developing information to explain the organization’s policies and procedures.
Principle #2 – Identifying Purposes
UNMARRY.CA collects Personal Information for the following purposes:
- to provide Services to you and your permitted users;
- to establish and maintain responsible commercial relations and to communicate with you in order to provide service. This includes, but is not limited to, communications relating to billing, payments, advertising, promotion and account verification;
- to respond to any correspondence you may direct to us;
- to understand, research, and improve our Services, including User feedback;
- to communicate with you regarding customer service issues and/or product or service issues;
- to direct advertisements to you about our company and our products and services that may be of interest to you;
- to enforce our Terms of Service and legal agreements;
- to provide you with system or administrative messages;
- to protect the integrity of our websites and our business;
- to meet legal and regulatory requirements; and
- for any other reasonable purposes for which you may have provided your express consent or in which your consent can be reasonably implied.
Non-Personally Identifiable Information
Principle #3 - Consent
The knowledge and consent of the individual are required for the collection, use, or disclosure of Personal Information, except in certain circumstances as described below,
In certain circumstances, Personal Information can be collected, used, or disclosed without the knowledge and consent of the individual. For example, legal, medical or security reasons may make it impossible or impractical to seek consent. When information is being collected for the detection and prevention of fraud or for law enforcement, seeking the consent of the individual might defeat the purpose of collecting the information. Seeking consent may be impossible or inappropriate where there is an emergency threatening the individual's life, health or security, or where the individual is a minor, seriously ill, or mentally incapacitated. In other instances, information may be publicly available.
Where appropriate, UNMARRY.CA will generally seek consent for the use or disclosure of the information at the time of collection. In certain circumstances, consent with respect to use or disclosure may be sought after the information has been collected but before use (for example, when UNMARRY.CA wants to use information for a purpose other than those identified above).
In obtaining consent, UNMARRY.CA will use reasonable efforts to ensure that a customer is advised of the identified purposes for which Personal Information collected will be used or disclosed.
The form of consent sought by UNMARRY.CA may vary, depending upon the circumstances and type of information disclosed. In determining the appropriate form of consent, UNMARRY.CA shall take into account the sensitivity of the Personal Information and the reasonable expectations of its customers and employees.
UNMARRY.CA will seek consent when the information is likely to be considered sensitive. Implied consent will generally be appropriate where the information is less sensitive. In certain circumstances, your consent may be implied by your actions. For example, providing us Personal Information to create an account or input into our document builder service is implied consent to use such information to provide you the associated services.
You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice, however, withdrawing consent may result in our inability to provide you with certain Services. In order to withdraw consent, you must provide notice to UNMARRY.CA in writing.
Principle #4 – Limiting Collection
UNMARRY.CA will limit the collection of Personal Information to that which is necessary for the purposes identified by UNMARRY.CA. UNMARRY.CA will collect information by fair and lawful means. UNMARRY.CA collects Personal Information from its Users for the purposes described under Principle #2.
Principle #5 – Limiting Use, Disclosure and Retention
Unless required by law, or in connection with a business transaction, UNMARRY.CA will not use or disclose or transfer Personal Information for any purpose other than those described above without first identifying and documenting the new purpose and obtaining your consent, where such consent may not reasonably be implied.
In the event your Personal Information is disclosed to a third party pursuant to a business transaction (including a potential sale or ), UNMARRY.CA will ensure that it has entered into an agreement under which the collection, use and disclosure of the information is related to those purposes that relate to the transaction.
Subject to the foregoing, only UNMARRY.CA’s and our Affiliates’ employees with a business need to know, or whose duties reasonably so require, are granted access to Personal Information about our Users. All such employees will be required as a condition of employment to contractually respect the confidentiality of your Personal Information.
UNMARRY.CA will retain Personal Information for only as long as required to fulfill the identified purposes or as required by law. Personal Information that is no required to fulfill the identified purposes will be destroyed, erased or made anonymous according to the guidelines and procedures established by UNMARRY.CA.
Principle #6 - Accuracy
To the extent that UNMARRY.CA directly collects Personal Information from Users, as opposed to Users disclosing Personal Information to UNMARRY.CA in using the Services or registering for an account, it will make reasonable efforts to ensure that such Personal Information is accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.
UNMARRY.CA will update Personal Information about Users as and when necessary to fulfill the identified purposes or upon notification by the individual.
Principle #7 - Safeguards
UNMARRY.CA will protect Personal Information by security safeguards appropriate to the sensitivity of the information.
UNMARRY.CA will protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. The nature of the safeguards will vary depending on the sensitivity of the information that has been collected, the amount, distribution and format of the information, and the method of storage.
We take administrative, technical and physical measures to safeguard your Personal Information against unauthorized access, unauthorized disclosure, theft and misuse. This includes limiting access of employees to, and the use of, your Personal Information through the use of passwords and graduated levels of clearance. We do not publish all of our security measures online because this may reduce their effectiveness. We take physical precautions to ensure that the computer servers on which your Personal Information is stored and archived are secure and in a controlled environment with limited access. We educate our employees with respect to their obligations to protect your Personal Information.
UNMARRY.CA makes its employees aware of the importance of maintaining the confidentiality of Personal Information. All of UNMARRY.CA's employees with access to Personal Information will be required as a condition of employment to contractually respect the confidentiality of Personal Information.
UNMARRY.CA will protect Personal Information it discloses to third parties through contractual agreements stipulating the confidentiality of the information and the purposes for which it is to be used.
Although we take precautions against possible breaches of our security systems, no company can fully eliminate the risks of unauthorized access to your Personal Information and no website is completely secure. We cannot guarantee that unauthorized access, hacking, data loss or breaches of our security systems will never occur.
Principle #8 - Openness
UNMARRY.CA shall make readily available to [Users] specific information about its policies and practices relating to the management of Personal Information.
UNMARRY.CA will make information about its policies and practices easy to understand, including:
- The title and address of the person(s) accountable for UNMARRY.CA's compliance with the policy and to whom inquiries or complaints can be forwarded;
- The means of gaining access to Personal Information held by UNMARRY.CA; and
- A description of the type of Personal Information held by UNMARRY.CA, including a general account of its use.
Principle #9 - Individual Access
Upon request, UNMARRY.CA will provide information to a User regarding the existence, use and disclosure of his or her Personal Information. UNMARRY.CA will respond to an application for individual access to Personal Information within a reasonable time and at minimal or no cost to the individual. ?A User may challenge the accuracy and completeness of the information and have it amended as appropriate.
NOTE: In certain circumstances, UNMARRY.CA may not be able to provide access to all the Personal Information it holds about a User. Exceptions may include information that is prohibitively costly to provide, information that contains references to other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons, or information that is subject to solicitor-client or litigation privilege. UNMARRY.CA will provide the reasons for denying access upon request.
Principle #10 - Challenging Compliance
UNMARRY.CA will maintain procedures for addressing and responding to all inquiries or complaints from Users about UNMARRY.CA's handling of Personal Information. UNMARRY.CA shall investigate all complaints. A User shall direct all inquiries or complaints involving UNMARRY.CA's handling of Personal Information or compliance with this policy or with PIPEDA to UNMARRY.CA's Privacy Officer.
The Privacy Officer will respond to all such inquiries or complaints within 14 business days of receipt. The Privacy Officer will make reasonable efforts to resolve all such complaints within 30 days of receipt of the initial complaint. If UNMARRY.CA finds a complaint to be justified, it will take appropriate measures, including, if necessary, amending its policies and procedures. ??
For more information, please contact our Privacy Office as follows: ?
Mail: 400 Applewood Crescent
Vaughan, ON L4K 0C3
Using the Site & Cookies
In order to improve the Site, we may use small files commonly known as “cookies”. A cookie is a small amount of data, which often includes a unique identifier that is sent to your computer or mobile phone (your “device”) from the Site and is stored on your device’s browser or hard drive. Cookies are used in analyzing trends, administering the site, tracking users’ movements around the site and to gather demographic information about our user base as a whole. We may generate reports based on the use of these technologies an aggregated basis
- Cookies that are required for the website to operate properly. If these are deactivated, the website will not function properly and may not be useable to that user.
- Performance cookies are used to monitor website performance. They allow us to correct errors and optimize our website for the best possible user experience.
- This statistical information we collect is used for internal review and to improve the content of our web site. It is not shared with any other organizations for commercial purposes.
You are able to disable cookies directly in your website browser. Visit www.AboutCookies.org for information. If you reject cookies, you may still use our Site, but your ability to use some features or areas of our site may be limited.
Cookies from third parties
We may use additional third parties with respect to Cookies and such parties will have their own privacy policies describing how they use information that they collect.
Children and Minors
Our Site and the Services offered on our Site are not directed to children under the age of 13 years.