We value the trust that you have placed in The Prompt Group Ltd. (“Prompt Group”, “we”, “our”, or “us”), and protecting your Personal Information is a priority. This Privacy Policy (“Policy”) describes our practices, including those of our subsidiaries and affiliates, regarding the collection, use, safeguarding, disclosure, transfer, access, disposal and other processing (collectively, “Processing”) of Personal Information of individuals who engage with us for our support, products or services, visit our website (https://www.thepromptgroup.com) (the “Website”), interact with our social media properties, or whose Personal Information is made available to us through Customer-authorized systems, data sources or third-party platforms in connection with our services.
For the purposes of this Policy, personal information (“Personal Information”) shall mean information that can identify an individual directly or indirectly through reasonably available information. In certain jurisdictions, Personal Information does not include information that is used solely for the purpose of communicating or facilitating communication with an individual in relation to their employment, business, or profession.
This Policy is our way of making sure you are fully informed of our Personal Information handling practices and policies relating thereto.
Effective Date
This Policy is effective as of the date “Last Updated”, above, and will remain in effect except with respect to any of its provisions that are changed in the future. We reserve the right to change this Policy at any time. Changes, modifications, additions, or deletions will be effective immediately upon their posting to the Website or upon you being otherwise notified. Your continued use of our Website or any other products and services after we post any such modifications will constitute your acknowledgement of the modified Policy and your agreement to abide and be bound by the modified Policy. We will also revise the “Last Updated” date found at the beginning of this Policy when we post changes to it.
Right to Withdraw Consent
Subject to certain legal and contractual limitations, you have the right to withdraw your consent from us Processing your Personal Information. This may limit our ability to provide you with our products and services, act on your behalf or engage with you as you would like. To withdraw your consent to certain Processing by we, you may declare to our designated Privacy Officer (contact information provided below) in writing, at any time, of your desire to withdraw consent. we will inform you of the implications of such withdrawal within thirty (30) days of your written request. Any withdrawal of consent will apply thereafter and not to information handling practices that have been previously undertaken based on prior consent. We may, however, collect, use or disclose Personal Information without your knowledge or consent in exceptional circumstances where such collection, use or disclosure is permitted or required by law.
Age of Consent
we will not knowingly obtain consent from those individuals who are minors, seriously ill, or mentally incapacitated and we shall therefore obtain consent from a parent, legal guardian or person having power of attorney of such an individual.
If you are an individual under the age of majority, you must access or use the Website only with the permission and involvement of your parent or guardian.
Collection and Processing of your Personal Information
Types of Personal Information Collected and Processed
The Personal Information which we may collect includes, but is not limited to:
Contact and identifying information including your name, mailing address, country of residence, email address, telephone number, gender and date of birth.
Transaction information including details of commercial or other transactions, such as the purchase of products or services, donations, sponsorship, and purchasing history and tendencies.
Payment information including your credit card details, bank account information, billing address, and payment or other information required when you purchase products or services.
User information including messages and images uploaded / shared as part of a public forum, message boards and user chats.
Usage information including information about how you use our Website, products and services.
Profile information including your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Marketing and communications information including your preferences in receiving marketing from us and third parties, and your communication preferences. and open rates and click through rates on email marketing campaigns through the use of marketing pixels.
Technical information including device type, device identifiers, IP address, MAC address, location, browser type, operating system and platform, protocol, sequence information, cookies, beacons, pixel tags, browser language and type, and domain name system requests.
Internet or other electronic network activity including browsing, session, interaction, search history, duration of use, frequency of use, material and pages viewed, time and date of access, number of bytes transferred, number of clicks per visit and other user behaviour related to our Website.
Information obtained from customer-authorized systems and data sources, including content management systems, websites, analytics and search platforms, advertising accounts, customer relationship management systems and other third-party platforms that a business customer directs us to access on its behalf, together with the knowledge bases, indexes, embeddings and other derived representations we create from that information in order to provide our services.
Other information which you voluntarily provide to us, our service providers, our employees, or our contractors.
We also collect, use and share aggregated information such as statistical or demographic data for any purpose. Aggregated information could be derived from your Personal Information but is not considered “personal information” in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage information to calculate the percentage of users accessing a specific Website feature. However, if we combine or connect aggregated information with your Personal Information so that it can directly or indirectly identify you, we treat the combined data as Personal Information which will be used in accordance with this Policy.
In addition, if you contact us, we may keep a record of your communication to help solve any issues you might be facing.
Purposes for Collection and Processing of Personal Information
Personal Information may be collected by we for purposes that include, but are not limited to:
Providing our products and services to our customers.
Placing orders with manufacturers and suppliers of our products.
Maintaining and improving our products and services and otherwise running and managing our business in the ordinary course, and keeping our records up to date.
Receiving communications from us in regard to e-news, emails, bulletins, notifications, newsletters, programs, events and activities.
Assisting you when you contact our customer support services, including to direct your questions to appropriate individuals, investigate and address any of your concerns, and to improve and monitor our customer support responses.
Administering and protecting our business and the Website, including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data.
Marketing and advertising our products and services.
Soliciting feedback on our products and services, offering tailored content, and providing promotional materials and product samples to you based on your interests.
Using data for business development and market research to understand demographics, interests, usage patterns, and other characteristics of individuals and to track and analyze trends and patterns.
Complying generally with all laws and applicable statutory requirements.
Permitting you to access and use our services and the Website.
Administering our contests, including to enroll participants, contact winners and send promotional materials.
Providing our products and services to business customers, including accessing customer-authorized systems and data sources, building and maintaining knowledge bases and related data stores, generating and publishing content on a customer’s behalf, and reporting on the results of those activities.
Methods of Collection of Personal Information
General
Personal Information may be collected by us in a number of ways, including in person, through our Website, by mail, by email, directly from customers and users, and from third parties, Customer-authorized systems, data sources and platforms where the applicable customer or other authorized party has directed or permitted us to access or collect the information.
If you provide information about a third party or authorize a third party to do so, we will assume you have taken proper measures to obtain informed consent.
Phone Calls
For the purpose of maintaining quality service, telephone calls to our customer services lines may be recorded. If your call is subject to a quality assurance program, you will be advised prior to speaking to a representative.
Cookies and Web Beacons
we may collect Personal Information through cookies on our Website. Cookies are small text files inside your computer that contain a unique identifier, allowing us to recognize you when you visit our Website again. This helps us to understand your preferences based on previous or current Website activity, allowing us to provide you with improved services, tailor our content to meet your needs and for advertising purposes. We also use cookies and navigational data to gather information regarding the date and time of your visit and the information for which you searched and viewed, or on which of the advertisements displayed on our Website you clicked.
The Website may use retargeting ads to advertise online. Retargeting uses cookies from third-party vendors like Google to track visitors. This tracking enables the third-party vendors to display our ads to people on various sites across the internet based on their visits to our Website.
We may also use web beacons (small pieces of data that are embedded in images on the pages of our Website) and auditing software to track page views and entry and exit points to and from our Website. We may use web beacons, cookies, customized links and/or similar technologies to determine whether electronic newsletters sent by us to those who have requested them from us have been opened and which links are clicked. Any data collected will only be used in an aggregate form and will not contain any Personal Information.
Some cookies may be automatically deactivated upon your access and use of the Website. However, unless you activate cookies, you may be unable to fully utilize and access all areas and features of the Website. You may activate cookies by visiting our Website and clicking “Activate Cookies”. Some third-party service providers may also place their own cookies on your browser. Note that this Policy only covers our use of cookies and does not include use of cookies by such third parties.]
Clickstream Data
When you visit we Website, we may also collect clickstream data (e.g. server address, domain name, device type, browsing software) which may be stored on the Website’s server. This information can be combined with information you have provided to us which will enable us to analyze and better customize your visits. We may use clickstream data for traffic analysis or e-commerce analysis of the Website, to determine which features of the Website are most or least effective or useful to you.
Mobile and Location Information
our Website features may be accessible from web-enabled mobile devices. The intent is to provide screens that are optimized for the size of the screen and operating systems. On some devices, functionality may be limited. If you use mobile-enabled services provided by our Website, we may receive information about you from your mobile device. This may also include information about your precise location if you have enabled location-based services on your mobile device. Some devices may allow you to opt-out of this collection or access, and in those cases, you may be able to subsequently stop the collection or access. Please review your device settings for more information.
Social Media
If you post a review, make a comment, or otherwise submit Personal Information on a public forum such as social media accounts or public forums, your communications may be viewable by the public. When voluntarily disclosing Personal Information about yourself to other users, we are unable to control what may be done with that content. You should take all necessary precautions to protect your private information by not posting or publishing any information that you do not want in the public domain. While we strive to provide the highest level of confidentiality, you should review your personal privacy settings to further restrict any or all parts of your profile or other certain content or information.
Accounts
Personal Information is collected by we when you create an account on our Website. In order to create and administer your account and authenticate you, we will collect your email address (i.e., your username) and a password that you create. You will also have the option to add information to your account profile, such as your full name, address, payment information, and organization. You are required to keep your username and password secure and not share it with anyone else.
Contests and Promotions
When you enter a contest or participate in a promotion, we may collect your name, address. Email address, phone number, and any additional information or content required for the contest or promotion, including to deliver a prize to you, or that you otherwise provide. We use this information to administer the contest or promotion.
Events
If you attend one of our events or webinars, we may collect your contact information and any other information you may provide us in connection with the event or webinar. We collect this information so that we can communicate with you about the event and contact you about future events.
Customer-Authorized Systems and Data Sources
Where a business customer engages us to provide services, that customer may authorize us to access its systems, accounts and data sources, or those of its own service providers, and to collect information from them. Personal Information collected in this way is collected on behalf of, and under the instructions of, that customer, and is processed in accordance with our agreement with that customer. We may ingest, copy, transform and store that information within our own infrastructure as necessary to build and maintain the applicable knowledge base and provide the services.
Other
we may collect Personal Information when you interact with us, including when you access the Website, register or create or edit your account, sign up to receive newsletters and information, fill out online surveys or forms, send or respond to our emails, or otherwise communicate with us.
Use of Automated Decision System
we utilizes technology which may collect Personal Information to make predictions, recommendations or decisions about you based exclusively on the automated processing of your Personal Information. You may request information with respect to any automated decisions that have been made based on the collection of your Personal Information, and the reasons and parameters which led to that decision. You may also correct the Personal Information that was used to render the prediction, recommendation or decision, and have the right to submit observations to the Privacy Officer who may review and re-assess the decision which was made by automated means.
Sharing of Personal Information with Third Parties
Although you are entering into an agreement to disclose your Personal Information to we pursuant to this Policy, we may delegate our authority for Processing of your Personal Information to third-party individuals and organizations who assist us with providing our products and services and administering our business, and for such other purposes as set forth below, including:
Suppliers, vendors, service providers, agents, contractors and affiliates, including companies we use for storage, processing, and delivery of our products and services.
Administrative and technical support, including cloud storage providers, software providers, IT support, and data analytics providers.
Public media and marketing, including companies we use for advertising, marketing, public relations, and press releases.
Parties in connection with proposed or actual financing, insuring, sale, securitization, assignment or other disposal of all or part of our business or assets.
Brands and other third parties that we have partnered with to provide exclusive rewards and savings to our members.
Artificial intelligence and machine learning platform providers, cloud hosting and data warehouse providers, and other subprocessors and service providers we engage to host, process, store and analyze information in the course of providing our products and services. Certain of these providers are located outside of Canada, including in the United States, in which case the information may be subject to the laws of those jurisdictions.
We do not store your payment information for online purchases with debit / credit cards, this is shared directly with our third-party payment providers including financial institutions and payment processors.
We may also disclose Personal Information in situations where we are legally required or permitted to do so. These situations may include criminal investigations, government tax reporting requirements, court orders, or instances where we believe the rights and safety of others may be at risk.
If you believe that a third party has inappropriately disclosed your Personal Information to us, please contact that third party directly. If the third party does not sufficiently respond to your inquiries, please let us know immediately.
Managing your Personal Information
Limiting the Collection and Processing of Personal Information
we takes care to ensure that Personal Information you provide to us is accessed internally only by individuals that require access to perform their tasks and duties, and externally only by service providers with a legitimate purpose for accessing it. We will not use or disclose any collected Personal Information outside of the purposes described in this Policy unless you have otherwise consented or it is required or permitted by law.
We do not sell, trade, rent or otherwise share for marketing purposes the Personal Information that we collect with third parties, unless you consent or authorize us to do so. We limit the Personal Information provided to the aforementioned affiliate and third-party service providers to the extent necessary for them to provide the services. We do not allow these third-party service providers to use your Personal Information for their own purposes and only permit them to access and process your Personal Information for specified purposes and in accordance with our instructions. Such service providers are required by contract to safeguard any Personal Information disclosed or transferred by us.
Accuracy of Personal Information
we takes all reasonable steps to keep your Personal Information as accurate, complete and up-to-date as necessary to fulfill the purpose for which your Personal Information has been collected. If desired, you may verify the accuracy and completeness of your Personal Information in our records with our Privacy Officer.
Despite our efforts, errors sometimes do occur. Should you identify any incorrect or out-of-date Personal Information in your file, we will remedy any such errors on a timely basis. You may request correction of the Personal Information we hold about you, though we may need to verify the accuracy of the new information you provide to us. If inaccurate Personal Information is mistakenly sent to a third party, we will communicate relevant changes to the third party where appropriate.
Making Changes to Your Account
You can review and change Personal Information that is displayed in your profile on the Website, and can close your account at any time. If you wish to have us delete all data about you held on our servers or otherwise, contact us and we can assist with this. Contact information can be found at the end of this Policy document.
Retention of Personal Information
we will store your Personal Information only for as long as is reasonably necessary to fulfill the purpose for which the Personal Information was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements. Once your Personal Information is no longer needed, we will securely and effectively dispose of it.
To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymize your Personal Information (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this anonymized information indefinitely without further notice to you.
We may use de-identified information to develop, improve, train or fine-tune artificial intelligence or machine learning models where the information has been processed so that it cannot reasonably be used to identify the applicable customer or any individual. We do not use identifiable customer data or Personal Information for model training or fine-tuning, and we do not attempt to re-identify de-identified information used for those purposes.
Request for Access to Personal Information and Processing
You may request access to your Personal Information, which enables you to receive a copy of the Personal Information we have collected from you and information about how we are Processing it, in a commonly used and structured electronic format.
We may need to request specific information from you to help us confirm your identity and right to access your Personal Information. This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. we may not always be able to comply with your request for access to Personal Information for specific reasons which you will be notified of, if applicable, in our response to your access request.
Request for Transfer of Personal Information
You may request the transfer of your Personal Information to a third party. we will provide your Personal Information to the third party you have chosen in a structured, commonly used, machine-readable format. This request may only apply to computerized Personal Information which you initially provided us and/or consented for us to use, or where we used the Personal Information to perform a contract with you.
Request for Information About Third Party Processing
Canadian residents have the right to receive information that identifies any third-party companies or individuals that we have shared your Personal Information with, as well as a description of the categories of Personal Information disclosed to that third party. You may obtain this information by contacting our Privacy Officer.
Opting Out of Certain Personal Information Processing
Canadian residents also have the right to opt-out of certain Personal Information Processing, including the disclosure of Personal Information to third parties which is not reasonably necessary for providing the services and goods you’ve requested or as otherwise required by law.
Protecting your Personal Information
Integrity and Security
we uses industry standard measures, including administrative, organizational, technical, and physical safeguards, to help protect Personal Information from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. We implement measures and processes to help us keep your Personal Information secure and to maintain its quality. We regularly review our security and related policies to adapt the technology as new threats evolve and monitor our systems to help ensure the highest level of availability. If you have any questions about the security of our Website, you can reach out to our Privacy Officer.
These measures include encryption of Personal Information in transit and encryption at rest within our production systems; role-based access controls and authentication requirements that limit access to personnel with a legitimate business need; logical separation of each customer’s data; logging and monitoring of access to systems containing Personal Information; contractual safeguards with the subprocessors and service providers we engage; and periodic review of our security practices and those of our providers.
Access to private, sensitive and confidential information, including Personal Information, is restricted to authorized employees or contractors with legitimate business reasons. our employees and contactors understand the importance of keeping your Personal Information private. All employees and contractors are expected to maintain the confidentiality of Personal Information.
Risks
Despite the foregoing security measures and significant steps we has taken to protect your Personal Information, no company can fully eliminate all security risks associated with the Processing of Personal Information. With that in mind, we cannot guarantee the security of any Personal Information provided to or received by us. We encourage you to keep watch for communications that are suspicious, and report any suspicious activity to us as soon as possible.
In the event there has been a breach of our security safeguards which involve your Personal Information, including the unauthorized access, use or disclosure of your Personal Information, loss of your Personal Information, or other breach, and where there is a risk that significant harm will come to you as a result of that breach, we will notify you and, if required, the applicable data protection authority.
Website Governed by this Policy
Our Website and our products and services are governed by the provisions and practices stated in this Policy. Our Website may contain links to third-party sites or applications that are not governed by this Policy. Although we endeavour to only link to sites or applications that share our commitment to your privacy, please be aware that this Policy will no longer apply once you leave our Website, and that we are not responsible for the privacy practices of third-party sites or applications. We therefore suggest that you closely examine the respective privacy policies of third-party sites and applications to learn how they collect, use and disclose your Personal Information.
Personal Information Outside of your Jurisdiction
Personal Information provided to our service providers may be stored outside of Canada. You acknowledge and agree that, as a result, your Personal Information may be processed, used, stored or accessed in other jurisdictions and may be subject to the laws of those jurisdictions. For example, information may be disclosed in response to valid demands or requests from government authorities, courts, or law enforcement in other countries.
If you are an individual resident in the province of Quebec, please note that your Personal Information may be transferred outside the province.
Addressing your Inquiries and Concerns
Your privacy is very important to us. We are happy to provide you with a copy of this Policy in an alternative, accessible format and to discuss any of its contents with you.
our Privacy Officer is responsible for the implementation of this Policy and monitoring our adherence to its terms and all applicable laws. The Privacy Officer also handles questions and concerns about our Policy, as well as Personal Information access requests and complaints. You may also seek advice from the Office of the Privacy Commissioner of Canada and/or Quebec’s Commission d’accès à l’information, and, if appropriate, file a written complaint with the relevant authority.
our Privacy Officer may be contacted at:
Privacy Officer, The Prompt Group Ltd.
Anton Sopov, Chief Executive Officer
1 Yorkville Avenue, Toronto, Ontario M4W 0B1
647-966-9127
anton@thepromptgroup.com