At Vintri Technologies Inc. (“Vintri”), one of our main priorities is the privacy of our customers and users. This Privacy Policy explains Vintri’s privacy and security practices with respect to all personal information in the possession and control of Vintri, and may be supplemented by specific policies, procedures, and practices.

Note to Residents of the European Union: In order to comply with the requirements of the European General Data Protection Regulation (GDPR) for European users, this Privacy Policy outlines the legal basis on which Vintri processes personal data (also referred to as personal information herein) and provides other information required by the GDPR. Vintri processes personal data when it has a lawful basis to do so in accordance with the GDPR. Generally, this means that Vintri processes personal data only where it has consent, where necessary to provide customers or users with information, products, or services, or where necessary to comply with legal obligations. Vintri may also process personal data where otherwise permitted by the GDPR for the purposes outlined in this Privacy Policy (for example, to communicate with customers or users and to respond to their requests). Please see below for further information.

Why does Vintri collect personal information?

Vintri’s legal basis for collecting and using the personal information described in this Privacy Policy depends on both the personal information we collect, and the specific context in which we collect the personal information. Generally speaking, Vintri may collect personal information for the following purposes:

  • To administer, plan, and manage the relationship with individual customers and users, and to communicate with them;
  • To provide individual customers and users with requested information, products, and/or services;
  • To better understand how Vintri may improve its products and services, to develop and conduct its business and operations, and for other internal business purposes;
  • To provide individual customers and users with information regarding current and future products and services or other developments with respect to Vintri and its partners (in accordance with Canada’s Anti-Spam Legislation – see below); and
  • To comply with applicable legal and regulatory requirements or to protect Vintri’s legal rights and property;

(collectively, the “Authorized Purposes”).

Vintri may collect personal information for other purposes where it has a legal duty or right to do so or where it has a good faith belief that it is necessary to protect the property or rights of Vintri.

Vintri does not collect personal information for any other purposes, unless it has the consent of the individual to whom it relates.

What personal information does Vintri collect?

The type of information that Vintri may collect from individual customers and users includes, for example, name, email address, address, phone number, and other information individuals choose to provide.

How does Vintri collect personal information?

Vintri only collects personal information about an individual customer or user with the individual’s knowledge and consent. Generally, this means that Vintri collects personal information directly from the individual to whom it relates, whether via Vintri’s websites, e-mail, telephone, fax, or in person. Occasionally, Vintri may collect personal information from third party sources, but only with the knowledge and consent of the individual or where otherwise authorized by law.

Visitors to Vintri’s websites should also be aware that anonymous technical information, in the form of log files, may be collected by Vintri as a result of a visit to Vintri’s websites. For example, this information may include the visitor’s IP address, browser type, operating system, domain name, access times and referring website addresses. Vintri uses this anonymous technical information for purposes such as diagnosing problems with Vintri’s servers, improving the operation and content of Vintri’s websites, and compiling aggregate and statistical information.

Vintri will not attempt to link or match such anonymous technical information with any personally-identifiable information unless Vintri has an individual’s consent, Vintri (or its service providers) have detected or reasonably suspect any unlawful use of Vintri’s services or a security breach, or Vintri has a legal duty or right to do so.

Vintri may use “cookies” on its websites. “Cookies” are small text files placed on computers that can collect and store a variety of information. Permanent cookies are stored indefinitely on a user’s hard drive unless manually deleted, while temporary cookies are automatically deleted from the user’s browser upon logging out of a website. Web browsers typically allow users to disable permanent and/or temporary cookies.

What about third party links accessible via Vintri’s websites?

Attachments on this site may include embedded content (e.g. videos, images, articles, etc.). from third party websites.

These websites may collect data about you, use technologies such as cookies, JavaScript, or Web Beacons, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

Note that Vintri has no access to or control over the technologies that are used by third parties, and that Vintri’s Privacy Policy does not apply to third party websites. Please consult the respective Privacy Policies of these third party websites for information regarding their privacy practices and instructions about how to opt-out of certain options.

When does Vintri use or disclose personal information?

Vintri only uses or discloses personal information as reasonably required to facilitate the Authorized Purposes listed above.

In some cases, Vintri may share personal information with third party service providers performing functions on Vintri’s behalf, including, for example, vendors that provide information technology services or provide analytics or assessment services.

Vintri does not otherwise use or disclose personal information unless it has an individual’s consent, it has a good faith belief that disclosure of the information is necessary to protect the rights or property Vintri, or it has a legal duty or right to do so.

Vintri does not rent, sell or trade customer lists or other personal information.  

Consent – Is there a choice?

Individual customers and users provide their consent to the collection, use, and disclosure of personal information by Vintri when they provide their information to Vintri or use its products or services.

Individuals can deny or withdraw their consent to Vintri’s collection, use and disclosure of their personal information at any time upon reasonable notice, subject to any legal or contractual requirements. However, if consent is denied or withdrawn, Vintri may not be able to provide certain products or services.

Vintri may use personal information to inform individual customers and users of current and/or new products or services or other developments that Vintri or its partners believe will be of interest to individuals in accordance with Canada’s Anti-Spam Legislation. Such communications may be made by way of telephone, text message, direct messaging, e-mail, fax or regular mail. Individual customers and users provide their consent to Vintri and its partners contacting them in this manner when they use Vintri’s products or services. Individuals may opt-out of receiving such communications by contacting Vintri at the address below.

How does Vintri protect the security of personal information?

Vintri has in place reasonable policies, procedures and safeguards (including physical, technological and organizational measures) designed to protect the security of personal information under its control.

The protection of personal information is of paramount concern to Vintri, and Vintri is prepared to take appropriate and timely steps in the event of any incidents involving personal information in accordance with applicable privacy laws.

Vintri makes every reasonable effort to ensure that personal information is accurate and complete. This may involve requesting further information or updates from individual customers or users. Vintri relies on individuals to notify it if there is a change to their personal information that may affect their relationship with Vintri.

Vintri retains personal information only as long as is reasonable to fulfill the purposes for which the information was collected, or for legal or business purposes.

Does Vintri provide access to personal information?

Vintri will provide individuals with access to the personal information Vintri holds about them in accordance with applicable laws. Vintri reserves the right to require that any request for access to personal information be made in writing. Generally, there is no cost for such access. However, Vintri reserves the right to charge such costs on a case by case basis in accordance with applicable laws. The individual making the request will be notified in advance if charges apply.

Vintri will correct or amend the personal information in its files where it can be shown that the information is incorrect or incomplete.

Storage and Processing

Vintri will store the personal information on its internal servers and/or with its services providers.

Vintri’s service providers may store and/or process personal information outside of Canada (including in the United States of America). When information is stored or processed outside of Canada, it may be subject to the laws of and be accessible by legal authorities in such other jurisdictions. Vintri has taken appropriate technical, organizational, and legal steps to secure this information.

What if I am accessing a Vintri site or product provided by my organization?

If an individual user is using or accessing a Vintri site product to which access is provided by an organization they are affiliated with, such as an employer or contractor, please note that that organization can:

  • Control and administer the user’s account, including controlling privacy-related settings of the account.
  • Access and process user data, which may include the interaction data, diagnostic data, and the contents of the user’s communications, and files associated with the user’s Vintri account.

If the individual user loses access to their account (in event of change of employment, for example), they may lose access to Vintri’s sites and the content associated with those sites.

When an individual user uses a Vintri site or product provided by an organization they are affiliated with, Vintri’s processing of personal information in connection with that site or product is governed by a contract between Vintri and the organization. Vintri processes personal information to provide the site or product to the organization and the individual user, and for Vintri’s legitimate business operations related to providing the product or site. Further detail regarding Vintri’s processing of personal information in connection with providing products or services to an organization can be obtained by contacting that organization.

What about personal information of children?

It is Vintri’s priority to provide additional protection for children while using the internet. Vintri encourages parents and guardians to observe, participate in, and/or monitor and guide their childrens’ online activity.

Vintri does not knowingly collect any personal information from children under the age of 13. If for any reason any individual thinks that their child has provided their personal information on a Vintri site, Vintri strongly encourages the individual to contact Vintri immediately, and Vintri will use its best efforts to promptly remove such information from its records.

GDPR Information

The GDPR sets out obligations and rights with respect to the personal data of residents of the European Union. Vintri is committed to ensuring that it complies with the requirements of the GDPR. As such, this section outlines additional information relevant to residents of the European Union only. Please see the remainder of Vintri’s Privacy Policy for more information on our privacy practices.

Your Rights Relating to Your Personal Data

Subject to some exceptions, the GDPR provides you with the following rights:

  1. Right of access: You have the right to information about whether and why Vintri processes your personal data and related information (for example, what personal data Vintri is processing).
  2. Right of rectification: You have the right to correct any inaccurate or incomplete personal data that Vintri holds about you.
  3. Right to erasure: You have the right to ask Vintri to delete personal data that it holds about you.
  4. Right to restrict or object to processing: You have the right to ask Vintri to limit or stop processing of your personal data in certain cases (for example, if the personal data Vintri is processing about you is inaccurate or is for direct marketing purposes).
  5. Right to data portability: You have the right to ask Vintri for a copy of personal data it holds about you and to transfer such data to another entity.
  6. Right to complain: Vintri encourages you to contact us at the contact information below if you have any questions or concerns with its personal data practices. However, you also have the right to complain to regulatory authorities in your jurisdiction. Please contact Vintri at the contact information below if you need information about the appropriate authority.

You may exercise these rights or find out more about these rights by contacting Vintri at the contact information listed below.

Retention and Storage of Personal Data

Vintri is based in Canada and processes personal data in Canada. The European Commission recognizes Canada as providing an adequate level of protection for personal data. Vintri’s service providers may process your personal information outside of Canada (such as in the United States of America). When your information is processed outside of the European Union, it may be subject to the laws of and be accessible by legal authorities in such other jurisdictions. Vintri  has taken appropriate technical, organizational, and legal steps to secure this information.

Online Privacy Policy Only

This Privacy Policy applies only to Vintri’s online activities and is valid for visitors to Vintri  websites with regards to the personal information that they share with and/or is collected by Vintri. This policy is not applicable to any information collected offline or via channels other than Vintri’s websites.

Consent

By accessing and using Vintri’s websites, the individual user or customer thereby consents to Vintri’s Privacy Policy, and agree to its terms.

Contact Vintri

Please do not hesitate to contact Vintri with any additional questions or requests for more information regarding its Privacy Policy, or to make any request for access to personal information or exercise any other rights outlined above, through email at privacy@vintritech.com

The foregoing policy is effective as of March 1, 2020. Vintri reserves the right to change this Privacy Policy at any time in accordance with applicable laws – please check Vintri’s website for updates to this Privacy Policy.