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Last Updated: November 16th, 2021

Your privacy and personal information are very important to us. The personal information Oggi Technologies Ltd. (“Oggi”, “Us”, “us”, “our”, “Our”, “We” and “we”) collect about you (“You”, “you”, “Your” or “your”) is managed in accordance with this Privacy Policy (“Policy” or “Privacy Policy”).  This Privacy Policy applies to the collection, use and disclosure of your personal information, including personal information relating to your use of the clearsource.ca website, and any and all services offered by Oggi (the “Services”), whether provided by or through our software and any and all other computer program(s), component(s) and module(s) offered by us and used by you and by or through the clearsource.ca website or affiliated sites providing Oggi services (the clearsource.ca website, together with all of the foregoing uses and services, to be hereinafter referred to as the “Site”).

BY APPLYING TO JOIN OGGI’S WAITLIST, BY SIGNING UP USING THE SITE, OR BY MAKING ANY OTHER USE OF THE SITE, YOU AGREE AND CONSENT TO THE PRACTICES AND POLICIES DESCRIBED IN THIS POLICY.  IF YOU DO NOT AGREE TO THESE TERMS AND CONDITIONS, DO NOT APPLY TO JOIN OGGI’S WAITLIST OR OTHERWISE SIGN UP FOR ANY SERVICES THROUGH THE SITE.

1. Privacy Commitment and Personal Information

We collect, use and disclose personal information to operate our business and as required by law. Personal information is information about an identifiable individual, or any information that identifies you as an individual, as defined in the Personal Information Protection and Electronic Documents Act and in any applicable provincial legislation, including the Alberta Personal Information Protection Act (PIPA).  It includes information that you provide to Oggi or that Oggi collects from any third party.

Personal information that we collect, use and disclose to and or from other sources may include, but is not limited to, your name, address, phone number, email, company name, and industry. Any personal information in the custody and control of a third party or agent acting on behalf of Oggi in another province or country is subject to the laws of that jurisdiction and may be collected, used or disclosed without your knowledge or consent where required or permitted by law.

2. Changes to Privacy Policy

This Policy describes our current privacy practices. We update this Policy on an ongoing basis to ensure consumers, applicants, customers and service providers, are aware of updates to our privacy practices, to streamline those practices and to comply with applicable laws. Please visit this site regularly for updates.

Oggi may, at any time and from time to time at its sole discretion, update, revise, supplement, replace, and/or otherwise modify this Policy and/or impose new or additional rules, policies, terms, or conditions on You.  Such updates, revisions, supplements, replacements, modifications, and additional rules, policies, terms, and conditions (collectively referred to as “Revised Terms”) will be effective immediately upon the Revised Terms being posted to the Site or by Oggi otherwise making them available to You (as the case may be).

In particular, when Oggi launches its vendor management and purchasing platform, Oggi will post Revised Terms governing your use of the ClearSource vendor management and purchasing platform and software to this Policy and post it to the Site, or will otherwise make them available to You.  Any continued use of the Site, and/or Oggi’s ClearSource vendor management and purchasing platform, following such posting of the Revised Terms to this Policy or by Oggi otherwise making them available to You (as the case may be), will be deemed to constitute acceptance of and consent to the Revised Terms.

3. Accountability

We are responsible for personal information in our possession or custody, as well as personal information transferred to a third party for processing. More details on our third parties are provided below under “Limiting Use, Disclosure and Retention”.

4. Information We Collect, and Limiting Collection

Oggi collects information about identifiable individuals.  Except where information is required to fulfill an identified purpose, you get to decide what information you want to share with us.  Oggi only collects such Personal information as is reasonably necessary for Oggi to fulfill the purposes as set out in this Privacy Policy.

Contact details. We may collect information you provide, such as your name, phone number, address, city, and email address, if you visit or use our Site or app, register or apply for one of our products or services, interact with us through social media or online ads, participate in surveys, or engage with us in any way. We may collect that information for uses as described in this Policy.  Such contact information that you provide us may be provided in connection with creating and maintaining an account registered with Oggi (an “Account”).

Information about you. If you apply or sign up for one of our products or services, depending on the product or service, we may collect information about you, including your name, address, company name, industry, and other details about you.  Such information may also include demographic information which is not unique to you, such as your postal code, age, gender, and preferences.  When you provide authorized user information, we expect that you have the authority to consent to its collection, use, and disclosure as outlined in this Policy. We may keep the information described above along with other information about you in our records, even after your Account is closed.

Digital and online information. We may collect information from your mobile and online activity; for example, information about your web browser, time zone, Internet Protocol (IP) address, mobile device ID, application and website use, and history. Cookies (small computer files that a website’s server places on your computer) collect information about your online behaviour. You can set your browser to reject cookies, but this may impair our ability to customize and test your experience, like remembering your preferred language or present location-specific information to you.  By using and browsing the Site, you consent to cookies being used in accordance with this Privacy Policy. If you do not consent, you must disable cookies or refrain from using the Site.  Cookies do not typically contain personal information, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

Usage information. If you sign up for one of our products or services, depending on the product or service, we may collect information regarding the use of our Site and application, including screens visited and in-app behavior in order to monitor and improve the app.

5. Identifying Purposes

We will clearly identify the purposes for which personal information is collected, used or disclosed prior to, or at the time of, collection, and as in our customer agreements and disclosures.

We may use your personal information to contact you. Your personal information allows us to contact you by various methods, including mail, email, SMS message, app push notification, and telephone at the contact points you have provided to us. We will contact you to respond to your questions, proactively provide you with information about your accounts with us, inform you about our products and services, and update you on changes to our Site, mobile app, and other digital services we provide. We may use your personal information to send you important updates about your application status and account opening disclosures, and to send you important or useful messages about your Account. When you communicate online or by email, you should be aware that sending information over the internet is inherently insecure, as it can be intercepted or manipulated and retransmitted.

We may use your personal information to provide you with offers, advertising and marketing. Elements of your personal information may be used to determine your suitability, or to directly communicate with you, for targeted advertising, marketing, promotions, rewards programs, research or contests. You may see advertisements for our products and services on our Site, mobile applications or on third-party websites, based on your online or mobile activity and information you have shared with third parties.

We may use your personal information to identify you on third-party platforms you already use (such as Facebook and Twitter) and provide you with ads through their marketing platforms. We may also use your information to identify you on third-party platforms (such as Facebook and Google), and then use the algorithms of those platforms to find other people with similar characteristics.

You can opt out of offers, advertising and marketing uses of your information, and opt out of the use of cookies by following the instructions in section 6 (Consent) below.

6. Consent

If you apply for a product or service, communicate with us, or provide personal information to us in any way, you acknowledge your consent to the collection, use and disclosure of such personal information as you provide to us or that we otherwise collect as set out in this Policy and applicable laws. If we want to use your personal information for a purpose that was not disclosed at the time of initial consent, consent will be sought at the time of this new purpose.

Updating consent. Subject to legal and contractual restrictions, you can, with reasonable notice to us, withdraw your consent to the collection, use, and disclosure of your personal information, other than the collection, use, and disclosure which is required for us to maintain your Account and to provide services that you sign up for and for which you were approved.

Opt out of mail, email and phone marketing. You can request that we not contact you for advertising, marketing, promotions, rewards programs, research or contests, by updating your privacy preferences associated with your Account or by otherwise updating your privacy preferences as set out herein. You should know that withdrawing your consent in these instances may result in you missing out on offers specific to your account.

To opt out of our email marketing list after you have opted in, you may use the unsubscribe link provided in any email marketing material you receive.

To update your privacy preferences outside of email marketing, you may do so by updating your privacy preferences associated with your Account, or by emailing privacy@oggitech.ca and with subject line *Email-Opt Out.

If you do not wish to receive cookies, or want to be notified of when they are placed, you may set your web browser to do so, if your browser so permits. If you wish to delete cookies, you may set your web browser to do so, if your browser so permits. You acknowledge and agree that if cookies are turned off or deleted, you may not be able to view certain parts of the Site or use certain of certain services available through the Site or certain features or functionalities thereof.

7. Limiting Use, Disclosure and Retention

We limit use, disclosure and retention of personal information to the purposes we identify, and as required by applicable laws.

Third parties. We do not sell or rent customer lists or personal information to others. We may share your personal information with service providers who perform services for your Account on our behalf (such as identity verification services, marketing, research, call centres, collections agencies, and other services as required to service you). When you engage with other companies directly, or contact us through their platforms, their use of the personal information they collect from you is subject to the terms of their privacy policies. We may share your personal information with regulators, courts or other institutions as required by law.

In particular:

  1. Third party verification providers – We may share your personal information with third party verification service providers, including those who maintain records relating to you telecommunications service providers, for the purposes of identity validation, risk assessment, and maintaining accurate contact details for your account.
  2. Marketing and research companies – We may share your information to understand and deliver products, services and offers that you, and others who are similar to you, may find useful. We may also share your information to block offers that you do not find useful.
  3. Regulators, courts, law enforcement and other government institutions – We may share your information to resolve concerns and as required by law.

Assignees. We may, at any time, sell, transfer or assign any or all of our rights to our Canadian business, including our interests, rights or obligations regarding your accounts with us. If we do so, we may share your personal information with prospective purchasers, transferees or assignees.  In such transactions, customer information shall be treated as a transferred business asset. In the event that Oggi (or all, or substantially all, of its assets) is acquired by a third party, Oggi’s customer information will be considered a transferred business asset.

8. Accuracy

We take steps to ensure that your personal information is as accurate, complete and up to date as is necessary for the purposes for which it is to be used.

If you believe that the personal information we have about you is not accurate or is incomplete, please contact us by updating your information through our web or mobile apps, by notifying any of our customer services lines or by email at privacy@oggitech.ca. If you move, change your phone number, or change your email address, you are required to update your information with us.

9. Safeguards

We use a variety of procedures and practices appropriate to the sensitivity of personal information to protect against loss, theft and unauthorized access. Access to your information is restricted to those individuals and parties who require access for the purposes set out in this Policy.

While we take all reasonable measures to protect data, there is always inherent risk when providing personal information.  The transmission of information and data over the Internet is inherently insecure, and there are no security systems that are completely safe or fool-proof against hacking or tampering.

10. Openness, Individual Access and Challenging Compliance

You can write to Oggi to request access to the personal information we have on file for you. We will provide you with the personal information we have, subject to certain considerations specified by law.

Oggi welcomes your comments regarding this Privacy Policy. If you would like more information on this Privacy Policy or Oggi’s organizational privacy policies, or if believe that Oggi has not adhered to the terms of this Privacy Policy, please contact Oggi’s designated Privacy Officer at privacy@oggitech.ca. We will use commercially reasonable efforts to promptly identify and remedy any failure by Oggi to adhere to the terms of this Privacy Policy.  You can also contact Customer Service for general privacy inquiries or concerns: privacy@oggitech.ca.