Privacy Policy

Last Updated: August 10, 2020

 

Introduction

At Riddell Consulting Group Inc. dba UNMARRY.CA (“UNMARRY.CA”, “We” or “Us” and terms of similar meaning), we are committed to your privacy.  This means we do not transfer, distribute, disclose, rent or sell any of your Personal Information to third parties except as provided for in this policy (the “Privacy Policy”) or as specifically consented by you.

UNMARRY.CA has developed policies and procedures consistent with the Personal Information Protection and Electronic Documents Act (“PIPEDA”), and other relevant privacy laws.  By accepting this Privacy Policy in registration or by visiting and using our legal information and self-help website and platform (the “Site”) and/or utilizing the services through the Site (the “Services”), you expressly consent to our collection, use and disclosure of your Personal Information in accordance with this Privacy Policy.  This Privacy Policy is incorporated into and subject to our Terms of Service.


Scope

This Privacy Policy governs our practices to the collection, use and disclosure of Personal Information that we collect from our customers and permitted users (typically our customers’ spouse or partner), and visitors to our company website (“Users”) through the Site and using our Services. 

Information We Collect

  1. 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:

If you are a customer, we will also collect:

Account Information

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. 

  1. 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.


Definitions

To better understand this policy, UNMARRY.CA has set out some basic definitions to use when reading and interpreting it.


Principles

UNMARRY.CA’s Privacy Policy is organized along the ten privacy principles of PIPEDA.

Principle #1 - Accountability

UNMARRY.CA is responsible for the Personal Information under our possession and control.  We have designated a Privacy Officer to be responsible for our compliance with this Privacy Policy and privacy legislation.

Accountability for UNMARRY.CA's compliance with the provisions of UNMARRY.CA's Privacy Policy rests with the Privacy Office within UNMARRY.CA, which shall designate one or more persons to be accountable for compliance with the UNMARRY.CA policy. Other individuals within UNMARRY.CA may be delegated to act on behalf of designated person(s) or to take responsibility for the day-to-day collection and processing of Personal Information. The Privacy Office has been created to ensure Users have a designated avenue to answer their privacy-related inquiries.

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:

Principle #2 – Identifying Purposes

Personal Information

UNMARRY.CA collects Personal Information for the following purposes:

Non-Personally Identifiable Information

In an ongoing effort to better understand and serve the users of our Site and  Services and improve our Service and Site functionality, we conduct research on our User demographics,  and behavior based on Personal Information and other information that we have collected.  This research may be used by UNMARRY.CA to analyze and improve our services to our customers and to direct advertising to our customers.  This research will be compiled and analyzed on an aggregate basis and this aggregate does not identify any individual and therefore is considered and treated as Non-Personally Identifiable Information under this Privacy Policy. 

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.

As noted above, UNMARRY.CA does not disclose your Personal Information to third parties.  Notwithstanding, your Personal Information may be transferred to third party suppliers, underlying platform licensors, contractors and agents, including our Mediators (“Affiliates”) who are contracted by UNMARRY.CA to assist it in providing services to you.  For example, when using our Mediation Services, our Mediators will be provided with the Personal Information you enter into the user documents you create in using our Services, such as separation agreement and financial statements.   Our Affiliates will only use your Personal Information for the purposes identified in this Privacy Policy.

Our Affiliates may be located outside of Canada, including in the United States, and your Personal Information may be collected, used, disclosed, stored and processed in such jurisdictions for the purposes described in this Privacy Policy.   UNMARRY.CA takes reasonable contractual or other measures to protect your Personal Information while processed or handled by such Affiliates. If your Personal Information is located outside Canada it will be subject to legal requirements in those foreign countries applicable to our service providers, for example, lawful requirements to disclose Personal Information to government authorities in those countries.

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:

UNMARRY.CA will make this Privacy Policy available online at www.unmarry.ca. On request, a copy of this Privacy Policy will be provided by mail.

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

An individual may address a challenge concerning compliance with this Privacy Policy to UNMARRY.CA's Privacy Officer.

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: ?

E-mail:    contact@unmarry.ca

Mail:       400 Applewood Crescent

              Suite 100

              Vaughan, ON L4K 0C3

              Canada


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

The cookies we use on the Site won't collect personally identifiable information about you and we won't disclose information stored in cookies that we place on your device to third parties.  We use cookies as follows:

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 use Google Analytics, a web analytics service provided by Google Inc. ("Google") on the Site. Google Analytics uses "cookies", which are text files placed on your computer, to help the Sites analyse how users use the Site. The information generated by the cookie about your use of the Sites (including your IP address) will be transmitted to and stored by Google on servers in the United States.  Google will use this information for the purpose of evaluating your use of the Site, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage.  Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google.  You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of the Sites.  By using the Site, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

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. 


General

UNMARRY.CA reserves the right to modify and amend this Privacy Policy from time to time in its sole discretion without prior notice. Any such amendment(s) will be posted on our Site and will be effective as of the date of posting.

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