This Policy is effective as of August 15th, 2022. We reserve the right to change this Policy at any time in accordance with applicable laws – please check our website for updates to this Policy.
Note to Residents of the European Union: To comply with the requirements of the European General Data Protection Regulation (GDPR) for European users, this Policy outlines the legal basis on which we process your personal data (also referred to as personal information herein) and provides other information required by the GDPR. We process personal data when we have a lawful basis to do so in accordance with the GDPR. Generally, this means that we process personal data only where we have consent, where necessary to provide you with information, products, or services, or where necessary to comply with our legal obligations. We may also process personal data where otherwise allowed by the GDPR for the purposes outlined in this Policy (for example, to communicate with you and to respond to your requests). Please see below for further information.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of information about you, including:
We only collect personal information about an individual with the individual's knowledge and consent. Generally, this means that we collect personal information directly from the individual to whom it relates, whether via our Platform, e-mail, telephone, or in person. Occasionally, we may collect personal information from third party sources, but only with the knowledge and consent of the individual or where otherwise authorized by law.
We are collecting your information for the following purposes:
(collectively, the "Authorized Purposes")
We may collect personal information for other purposes where we have a legal duty or right to do so or where we have a good faith belief that it is necessary to protect the property or rights of DNA. We do not collect personal information for any other purposes unless we have the consent of the individual to whom it relates.
We only use or disclose personal information as reasonably required to facilitate the Authorized Purposes listed above.
We generally disclose information we gather from you through the Platform to the following types of third parties and as otherwise set forth in this Policy or as specifically authorized by you:
In some cases, we may share personal information with third party service providers performing functions on our behalf, including, for example, vendors that provide information technology services, provide analytics or assessment services, or otherwise support the Platform.
DNA has a close working relationship between the affiliated companies within its corporate structure. Personal information may be shared between these organizations to facilitate the Authorized Purposes listed above in accordance with this Policy.
Laws and Legal Rights
We may disclose your information (including personally identifiable information) if we believe in good faith that we are required to do so in order to comply with an applicable statute, regulation, rule or law, a subpoena, a search warrant, a court or regulatory order, lawful requests by public authorities, including to meet national security or law enforcement requirements, or other valid legal process. We may disclose personally identifiable information in special circumstances when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating a contract with us, to detect fraud, for assistance with a delinquent account, or to protect the safety and/or security of our users, the Platform or the general public.
Sale of Business
We reserve the right to transfer information to a third party in connection with a sale, merger or other transfer of all or substantially all of the assets of DNA or any of its affiliates, or a portion of DNA or any of its affiliates, or in connection with a strategic investment by a third party in DNA or its affiliates, or in the event that we discontinue our business or file a petition or have filed against us a petition in bankruptcy, reorganization or similar proceeding.
Third Parties Generally
We may provide to third parties non-personally identifiable information, including where such information is combined with similar information of other users of the Platform. For example, we might inform third parties regarding the number of unique users who use the Platform, the demographic breakdown of our users of the Platform, or the products and/or services purchased using the Platform and the vendors of such products and services. In addition to the above, when users use our Platform, third parties (including without limitation third-party analytics service providers and commercial partners) may directly collect personally identifiable and non-personally identifiable information about our users' online activities over time and across different websites. The third parties to which we may provide or who may independently directly collect personally identifiable and non-personally identifiable information may include providers of analytics services (including vendors, analytics services providers, and website tracking services), affiliates and other actual or potential commercial partners, and other similar parties. For greater clarity, we may disclose aggregated, non-personally identifiable information about individuals who use or access the Platform without restriction.
We are committed to securing your information and keeping it confidential. We have done all in our power to prevent data theft, unauthorized access, and disclosure by implementing the latest technologies and software, which help us safeguard all the information we collect online. We have in place reasonable policies, procedures and safeguards (including physical, technological and organizational measures) designed to protect the security of personal information under our control.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect individual's personal information, we cannot guarantee the security of personal information transmitted to our Platform or otherwise via the Internet. There is also some risk that others could find a way to thwart our security systems. As a result, while we strive to protect individual's personal information, we cannot ensure or warrant the security or privacy of any information individuals transmit to us, and such individuals do so at their own risk.
We make every reasonable effort to ensure that personal information is accurate and complete. This may involve requesting further information or updates from individuals. We rely on individuals to notify us if there is a change to their personal information that may affect their relationship with DNA.
The protection of personal information is of paramount concern to us, and we are prepared to take appropriate and timely steps in the event of any incidents involving personal information in accordance with applicable privacy laws. We retain personal information only as long as is reasonable to fulfill the purposes for which the information was collected, or for legal or business purposes.
Please note that cookies don't allow us to gain control of your computer in any way. They are strictly used to monitor which pages you find useful and which you do not so that we can provide a better experience for you. If you want to disable cookies, you can do it by accessing the settings of your internet browser.
Please note that we use third party analytics services for our website, such as Google Analytics. There is more information about how these service providers including Google collect, use, and process data on their respective websites including at http://www.google.com/policies/privacy/partners/.
Pages of our website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
At some point, you might wish to restrict the use and collection of your personal information. You can achieve this by doing the following:
Your personal information will be used when we need to send you promotional materials. DNA and its affiliates may use personal information to inform individuals of current and/or new products or services or other developments that we or our affiliates or partners believe will be of interest to individuals in accordance with applicable laws including Canada's Anti-Spam Legislation (CASL). Such communications may be made by way of telephone, text message, direct messaging, e-mail, fax or regular mail. Individuals provide their consent to us and our affiliates and partners contacting them in this manner when they use our products or services. Individuals may opt-out of receiving such communications by contacting us at the address below.
Individuals provide their consent to the collection, use, and disclosure of personal information by us when they provide their information to us or use our products or services.
Individuals can deny or withdraw their consent to our 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, we may not be able to provide certain products or services.
We will provide individuals with access to the personal information we hold about them in accordance with applicable laws. We reserve 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, we reserve the right to charge such costs on a case by case basis in accordance with applicable laws. The individual will be notified in advance if charges apply. We will correct or amend the personal information in our files where it can be shown that the information is incorrect or incomplete.
We will store personal information on our internal servers and/or with our services providers.
Our 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. We have taken appropriate technical, organizational, and legal steps to secure this information.
The GDPR sets out obligations and rights with respect to the personal data of residents of the European Union. DNA 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 the Policy for more information on our privacy practices.
Subject to some exceptions, the GDPR provides you with the following rights:
You may exercise these rights or find out more about these rights by contacting us at the contact information listed below.
DNA 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. DNA'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. We have taken appropriate technical, organizational, and legal steps to secure this information.
For more information about our privacy practices, if you have questions, if you would like to make a complaint, a request for access, or exercise any other rights outlined in this Policy, please contact our Privacy Officer at the following address: by email email@example.com or by mail using the details provided below: 553 Riverfront Ave SE Calgary, AB T2G 0G1