Our Privacy Policy

 Goodable Inc. and its affiliates (collectively, “Goodable”, “we”, “our” or “us”) recognize the importance of privacy. The purpose of this privacy statement (“Privacy Statement”) is to inform you (“you” or “your”) about our privacy practices, including how we collect, use and disclose your Personal Information (as defined herein).

This Privacy Statement applies to all of our operations in Canada or operations in connection with Canada, unless we have provided you with a separate privacy statement for a particular product, service or activity. 

This Privacy Statement is current as of the “last updated” date which appears at the top of this page. We may modify this Privacy Statement from time to time and we will provide you of notice of changes to this Privacy Statement. When changes are made to this Privacy Statement they will become effective on the date set out in any notice or on the “updated” date as published in a revised Privacy Statement posted on our website.

Please review this Privacy Statement carefully. By submitting your Personal Information to us, by registering for or using any of the services we offer, by using our website, or by voluntarily interacting with us, you consent to our collecting, using and disclosing your Personal Information as set out in this Privacy Statement, as revised from time to time.

Goodable services may allow you to access services provided by others and to interact with other service providers. Where you choose to use services provided by others or interact with other service providers, you consent to us disclosing your Personal Information to those third party services providers to facilitate your use or interaction with those services and providers.

  This Privacy Statement covers the following topics: 

• Meaning of Personal Information
• Your Consent to Collection, Use and Disclosure
• Personal Information We Collect
• How We Use Your Personal Information
• How We Share Your Personal Information
• Opting Out of Communications
• Retention of Personal Information
• Information Security
• Accessing and Updating Your Personal Information
• International Transfer and Storage of Information
• Third Party Services
• Children’s Information
• How to Contact Us

"Personal Information" means information about an identifiable individual as described under Canadian privacy laws. This information may include (without limitation) your name, mailing address, e-mail address, telephone number, other contact information you provide to us, professional or employment information, banking information, and payment information. 

Personal Information does not include any business contact information that is solely used to communicate with you in relation to your employment, business or profession, such as your name, position name or title, work address, work telephone number, work fax number or work e-mail address.

Personal Information also does not include information that has been de-identified, anonymized, or aggregated in such a way that there is no serious possibility it can be used, or where it could not be used in reasonably foreseeable circumstances, to identify an individual whether on its own or in combination with other information.

We collect, use and disclose your Personal Information with your consent or as permitted or required by Canadian privacy laws. How we obtain your consent (i.e., the form we use) will depend on the circumstances, as well as the sensitivity of the information collected. Subject to applicable laws, your consent may be express or implied, depending on the circumstances and the sensitivity of the Personal Information in question. 

If you wish to withdraw your consent to our collection, use or disclosure of your Personal Information, please contact us using the contact information in the “How to Contact Us” section below. However, before we implement the withdrawal of consent, we may require proof of your identity. In some cases, withdrawal of your consent may mean that we will no longer be able to provide you with certain products or services.

If you provide Personal Information about another individual to us, it is your responsibility to obtain the consent of that individual to enable us to collect, use and disclose his or her information as described in this Privacy Statement.

The Personal Information we collect is generally in one or more of the following categories.

Products and Services. For individuals located in Canada who use our products and services, we may collect information from you or from your use of our products or services.

· We collect Personal Information that you submit through your use of our products or services, such as (without limitation) your name, e-mail address, telephone number, other contact information, banking information, and payment information. 

· We may also automatically collect usage data that is identifiable with you when you use our products and services.

Website. For individuals located in Canada who visit our website and located at https://www.goodable.co or any of our related websites, including to access the Goodable platform (collectively, “our website”), we may collect information from you or from your activities on our website.

· Like most websites and other Internet services, we may collect certain technical and device information about your use of our website. Such information may include your Internet protocol address, information about your device, browser and operating system, and the date and time of your visit.

· We may use “cookies” or enlist third party services which use cookies to track your preferences and activities on our website. Cookies are small data files transferred to your computer’s hard-drive by a website. They keep a record of your preferences, making your subsequent visits to that website more efficient. Cookies may store a variety of information, including the number of times that you access a website, your language preferences and the number of times that you view a particular page or other item on that website. The use of cookies is a common practice adopted by most major websites to better serve their users. Most browsers are designed to accept cookies, but they can be modified to block cookies. Without cookies some of our website’s functions may not be available.

· We may also use “web beacons” to better understand how our website is being used and to enhance your online experience. Web beacons are Internet tools that help us determine, for example, whether a page of our website has been viewed.

You have a variety of tools to control the data collected by cookies, web beacons, and similar technologies. For example, you can use controls in your internet browser to limit how the websites you visit are able to use cookies and to withdraw your consent by clearing or blocking cookies.

Other Interactions. For individuals located in Canada who otherwise interact with us, whether in person, by phone or email, through social media or otherwise, including individuals who might be interested in acquiring our products or services, who sign-up to receive newsletters or other communications, who respond to surveys and questionnaires, or who submit testimonials or other feedback, we may collect information that you provide to us during these interactions. This information may include your name, e-mail address and other contact information.

  We may use your Personal Information for purposes such as:

· providing you with our products and services and supporting your use of our products and services;

· to improve the effectiveness of Goodable services;

· monitoring the usage of our products and services to support their proper functioning and further improvement;

· analyzing the needs and activities of our customers to help us better serve them;

· generating de-identified data to conduct research and analysis related to our business, products and services;

· responding to inquiries and other requests; 

· collecting opinions and comments about our products and services;

· providing you with information that we think may interest you, including information about our products and services; and

· investigating legal claims.

We may use your Personal Information for purposes for which we have obtained your consent, and for such other purposes as may be permitted or required by applicable Canadian privacy laws.

We may use the information we collect to advertise third party products and services or targeted advertising of Goodable products and services across third party websites or service offerings (the “Targeted Advertising”). You may opt-out of the Targeted Advertising services at any point by notifying the Company directly using the contact information in the “How to Contact Us” section below. We will endeavour to respond to your opt-out request promptly, but we ask that you please allow us a reasonable time to process your request.

  Goodable services may allow you to access services provided by others and to interact with other service providers. Where you choose to use services provided by others or interact with other service providers, we will disclose your Personal Information to those third party services providers to facilitate your use and interactions with those services and providers. 

We rely on third party services providers (including affiliates) to perform a variety of services on our behalf, such as (without limitation) hosting, data storage and processing service providers, telecommunications carriers, email providers, telephone and technical support providers, and research and analytics providers. 

If we provide your information to service providers, then we require that the service providers keep your Personal Information secure, and only handle it for limited purposes for which it is provided. We do not authorize the service providers to disclose your Personal Information to unauthorized parties or to use your Personal Information for their own purposes. If you would like more information about our service providers, please contact us using the contact information in the “How to Contact Us” section below. We may share your Personal Information with members of our corporate family for the purposes of facilitating the improvement of, or your experience with, our products or services. The Personal Information we share with our affiliates is subject to our privacy policies and practices described in this Privacy Statement. 

Additionally, we may use and disclose your information when we believe such use or disclosure is permitted, necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce the terms of the agreements for our products and services; (e) to protect our rights, operations or property; (f) to allow us to pursue available remedies or limit the damages that we may sustain. In addition, we may transfer your Personal Information and other information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, brands, affiliates, subsidiaries or other assets, or other business transaction.

If we otherwise intend to disclose your Personal Information to a third party, we will identify that third party and the purpose for the disclosure, and obtain your consent. 

  If you no longer want to receive marketing-related emails from us, you may opt-out of receiving marketing-related emails by clicking the “unsubscribe” link at the bottom of any email you receive from us. You may also opt-out by contacting us directly using the contact information in the “How to Contact Us” section below. 

We will endeavour to respond to your opt-out request promptly, but we ask that you please allow us a reasonable time to process your request. Please note that if you opt-out from receiving marketing-related emails, we may still need to send you communications about your use of our products or services, or other matters.

We will use, disclose or retain your Personal Information only for as long as necessary to fulfill the purposes for which that Personal Information was collected and as permitted or required by Canadian privacy laws. 

  We have implemented physical, organizational, contractual and technological security measures with a view to protecting your Personal Information from loss or theft, and unauthorized access, disclosure, copying, use or modification. We have taken steps to ensure that the only personnel who are granted access to your Personal Information are those with a business ‘need-to-know’ or whose duties reasonably require such informa

Despite the measures outlined above, no method of information transmission or information storage is 100% secure or error-free, so we unfortunately cannot guarantee absolute security. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any information that you provided to us has been compromised), please contact us immediately using the contact information in the “How to Contact Us” section below.

You may make a written request to review any Personal Information about you that we have collected, used or disclosed, and we will provide you with any such Personal Information to the extent required by applicable laws. You may also challenge the accuracy or completeness of your Personal Information in our records. If you successfully demonstrate that your Personal Information in our records is inaccurate or incomplete, we will amend the Personal Information as required.

We may require that you provide sufficient identification to fulfill your request to access or correct your Personal Information. Any such identifying information will be used only for this purpose.

You may also contact us at anytime via the "Contact Us" section on our website to request that your Personal Data be deleted. Goodable will comply with local laws and regulations to the best of our ability.

Your Personal Information may be stored and processed at our offices in Canada or at the offices of our third party service providers, or at data centers managed by us or third party service providers, in the United States. Other jurisdictions may have different data protection rules than Canada. While your Personal Information is outside of Canada, it is subject to the laws of the country in which it is located. Those laws may require disclosure of your Personal Information to authorities in that country. For written information about our policies and practices regarding service providers outside of Canada, contact our Privacy Officer using at the contact information in the “How to Contact Us” section below.

Goodable services may allow you to access services provided by others and to interact with other service providers. These services provided by others are subject to the privacy practices of the third-party service provider and are governed by their privacy statements and policies, not those of Goodable. We may also provide links to third party websites for your convenience and information. This Privacy Statement does not extend to any services, products or websites provided by third parties. We do not assume responsibility for the privacy practices of such third parties, and we encourage you to review all third party privacy policies prior to using third party services, products or websites.