First impressions are everything.

PRIVACY POLICY

We’ve updated our Privacy Policy. We’ve increased transparency by providing you with more information about the data we collect, how we use, and when we share it. We’ve also included details about your rights regarding your personal data and how to contact us. We have not changed our commitment to your privacy. There is nothing you need to do, but we do encourage you to review the updated Privacy Policy.

‍

PRIVACY POLICY HIGHLIGHTS

We collect personal data that you provide us directly, and we also obtain personal data through the use of cookies and other technologies, as well as from third parties. The categories of information may include:

• Identifiers (for example, name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers)
• Personal information (for example, name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, education, employment, employment history, employee health information, bank account number, credit card number, debit card number, or any other financial information)
• Commercial information (for example, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)
• Internet activity (for example, browsing history, search history, information on interactions with a website, our services, or advertisements)
• Geolocation data (for example, physical location or movements)
• Professional or employment-related information (for example, current or past job history)
• Inferences drawn from other personal information (for example, profile reflecting preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes)

We use this information, and share this information with our service providers, for the following commercial and business purposes:

• To fulfill or meet the reason for which the information is provided.
• To provide you with information, products or services that you request from us.
• To provide you with information concerning our products or services, or events or news, or opportunities that may be of interest to you.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for account management, billing, collections, usage analytics and compliance with terms.
• To improve our website and present its contents to you.
• For testing, research, analysis and product development.
• As necessary or appropriate to protect the rights, property or safety of us, our customers or others.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

Pragmatica does not directly sell your personal information in the conventional sense (i.e., for money). Like many companies, however, we use services that help deliver interest-based ads to you. We and our advertising partners may collect certain information, including cookies and similar information stored on your browsers, advertising identifiers on your mobile devices, and/or the IP address of your devices when you visit our sites or use our apps. We and our partners use that information to deliver online advertisements to you on your devices and tailor those ads to your interests. Making this information available to these companies may be considered a “sale” under the California Consumer Privacy Act (“CCPA”).

FULL PRIVACY POLICY

We at Pragmatica ("Pragmatica Web Solutions Inc." or "we" or "us" or "our") know that your privacy is important. This privacy policy ("Policy") is designed to assist you in understanding how we process your personal data when you (1) use our websites, web applications, or our mobile applications (and other add-on applications, (2) subscribe to or use our services or other related services on which we post a direct link to this Policy, (3) visit our offices, (4) contact us or we contact you (including through telephone, text messaging (SMS/MMS), email, and website channels), or (5) otherwise interact with us. Personal data does not include information which is not personally identifiable or which cannot be reasonably associated or linked with an individual or household. Please read this Policy carefully to learn how we collect, use, share and otherwise process your personal data, and to learn about your rights and choices regarding our processing of your personal data.

Within the scope of this Policy, Pragmatica is the business that makes the decisions about the processing of your personal data (also known as the “data controller”), unless expressly specified otherwise. This Policy does not cover any other data collection or processing, including the data related to our customers’ clients which we host for our customers (and for which we act as a “data processor” or “service provider”) via the Pragmatica sales and marketing software platforms ("Platform").

Collection of Your Personal Data

What We Collect. In some situations you may provide us with your personal data, which could include your name, street address, telephone number, email address, job title, payment card number, other financial account number(s), mother's maiden name or other family names, date and place of birth, criminal record, arrest record, driver's license number, photographic image, the types of information specified in the Summary of Data Use, Collection, and Disclosure section of this Policy, and any other information we collect about you that by itself is not personally identifiable information but if combined with personally identifiable information could be used to personally identify you.

You may provide us with personally identifiable information when you enter a sweepstakes or contest; complete a survey; apply for a job; make a purchase; download an e-book; request customer support; evaluate or subscribe to certain services or Platform, sign up for email or text message (SMS/MMS) notifications and/or newsletters; register for our Platform, or register and/or set up an account/profile to access, visit and/or use our website and/or Platform; provide comments, reviews, feedback, or testimonials about our products or services, request support or information about our services or Platform; and participate in any other transactions or interactions between you and Pragmatica.

Information We Automatically Collect. When you interact with us by computer, telephone, mobile phone or other device, we automatically collect certain information. This information may include, without limitation: telephone number, geographical location and IDs of your computer, mobile or other device; bandwidth used; system and connection performance; browser type and version; operating system; referral source; your interactions with us, length of visit; page views; Internet Protocol address or other unique identifier; hardware model; mobile network information; and time zone.

Cookies, Web Beacons, and other Technologies. When you interact with us, we try to make that experience simple and meaningful. When you visit our website, use our Platform, or receive email from us, our servers may send cookies, web beacons, and similar technologies to your device. The data collected may include how you navigate around a web page and the most commonly clicked links on a specific web page. Certain technical information, such as your browser version and operating system, are also collected. We may also from time to time engage third parties to track and analyze non-personally identifiable usage and volume statistical information from visitors to our websites to help us administer our websites and improve their quality. Such third parties may use cookies, web beacons, and similar non-cookie technologies to help track visitor behavior, how you interact with a website (including how you navigate around a web page and the most commonly clicked links on a specific web page).

Refer a Friend. If you choose to use our referral service to tell a friend about us or our services, we will ask you for your friend's name and email address. We will use the information you provide to automatically send your friend an email or other communication inviting him or her to visit our website. Your friend can opt out of receiving future promotional/marketing messages from us as described in the Unsubscribe section of this Policy. Treatment of your friend's information will be subject to the terms of this Policy.

Telephony Information. If you use certain features of our services or Platform, we may collect telephony information (like phone numbers, time and date of calls, duration of calls, text message (SMS/MMS) routing information and types of calls), device event information (such as crashes, system activity, hardware settings, browser language), and location information (through Internet Protocol address, Global Positioning Satellite information, and other sensors that may, for example, provide us with information on nearby devices, Wi-Fi access points and cellular towers).

Personal Data We Collect From Other Sources. We may also collect information about you from other sources, including third parties from whom we have purchased personal data, and combine this information with personal data provided by you. This helps us to update, expand and analyze our records, identify new customers and create more tailored advertising to provide services that may be of interest to you. We may collect personal data from third party providers of business contact information, including mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), Internet Protocol addresses, social media profiles, LinkedIn URLs and custom profiles, for purposes of targeted advertising, delivering relevant email content, event and services promotions and profiling.

Disclosures by Children. We believe that protecting the privacy of the very young is especially important and for that reason we will never collect or maintain information on our Site from those we actually know are under the age of 16. Our websites and Platform are intended for business audiences, and no part of our websites or Platform is structured to attract anyone under 16.

Third Party Sites. We may provide links to third party websites. Please note that the privacy and other policies of any such third party website may differ materially from this Policy. We strongly recommend that you review the privacy policies of any such third party prior to submitting personal data. Pragmatica has no control over and is not responsible for the information practices of other websites, including those to which we may link and those which may link to us.

Use of Widgets and Social Media. We may provide widgets that make it possible to share information on third-party services. We may also include social media features, such as the Facebook® or Twitter® button and similar widgets and interactive mini-programs that run on our site (each, a “Feature”). To the extent we use these Features, they may collect your Internet Protocol address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social media Features and widgets are either hosted by a third party or hosted directly by us. Your interactions with these Features are governed by the privacy statement of the company providing the Feature or widget.

Use of Testimonials. We may select and post testimonials about us or our Platform, which may contain personal data such as your name and/or the city, state, or country in which you live. We will obtain your consent prior to posting any testimonial with your name. If you post such content, it will be available to other customers and visitors. Your posting may also become public and we cannot prevent such information from being used in a manner that may violate this Policy or the law. If you would like us to remove or delete your name or testimonial, you may contact Pragmatica using the information in the Contact section of this Policy. Note that copies of information that you have updated, modified, or deleted may remain viewable in cached and archived pages for a period of time.

Reviews. We may post reviews provided by you about us or our Platform, which may contain personal data such as your name and/or the city, state, or country in which you live. When submitting your review, you are giving us permission to post your review. If you post such content, it will be available to other users of our website or Platform. Your posting may also become public and we cannot prevent such information from being used in a manner that may violate this Policy or the law. If you would like us to remove your name or review from our website, you may contact Pragmatica using the information in the How to Contact Us section of this Policy. Note that copies of information that you have updated, modified, or deleted may remain viewable in cached and archived pages for a period of time.

Your Choices. You have choices with respect to your personal data, and can choose to not provide personal data to us. Our Platform may require some personal data to provide you with a service. If you choose not to provide data required to provide you with a service or feature, you cannot use that service or feature. We may also need to collect personal data as required by law or to enter into or carry out an agreement with you. If you do not provide any such required personal data, we will not be able to enter into the agreement. If you are already using our Platform and choose not to provide us with any necessary personal data we may have to suspend or cancel the impacted services.

Use of Your Personal Data

General. We may process your personal data as described in this Policy to perform our contract or other obligations we have with you, for our legitimate interests or those of a third-party, as needed or permitted to comply with law, or based on your consent. These uses may include:

• providing our websites, services, and functionality (for example, to perform our contract with you for the use of our websites and services and to fulfill our obligations under applicable terms of service or to operate and administer our websites and to provide you with content you access and request);
• providing customized service content (for example, so that we can provide you with customized content or keep track of preferences you specify);
• maintaining and improving the security and safety of our websites and services (for example, by tracking use of our websites and services, creating aggregated, non-personal data, verifying accounts and activity, investigating suspicious activity and enforcing our terms and policies, to promote the safety and security of the services, systems and applications and in protecting our rights and the rights of others);
• account management (for example, managing your subscription or other registration to provide you with services, servicing your account, providing information related to your purchase, use, payments and invoices, and contacting you about your purchase);
• handling contact and user support requests (for example, when you contact us, request contact, or request user support, including by telephone, email, webform or otherwise, to fulfill your requests, assist you with your use of our Platform, and communicate with you);
• providing you with service, company updates, and other notifications (for example, if you are a customer, we may provide you with company news, and service information);
• managing event registrations and attendance;
• managing contests/promotions/sweepstakes (for example, if you register for a contest, promotion, or sweepstakes, then and subject to any additional applicable rules);
• managing and processing payments including facilitating payment card transactions initiated directly with us or through a third-party payment processor and related authentication, security and fraud prevention activities; (for example, if you are a customer purchasing services from us or using our services to process payment card transactions);
• developing and improving our websites, services, and user experience (for example, to debug and repair any errors impacting functionality, to assess systems capacity requirements, to analyze trends and to track your usage of and interactions with our websites and services for developing and improving our websites and services and providing our users with more relevant content and service offerings);
• auditing and reviewing compliance with applicable usage terms, policies, laws, rules, and regulations;
• registering office visitors (for example, to protect our offices and our confidential information against unauthorized access);
• displaying personalized advertisements and content (for example to conduct marketing research, advertise to you, provide personalized information about us on and off our websites and to provide other personalized content based upon your activities and interests);
• identifying customer opportunities and sending marketing communications (for example, to ensure that we are meeting the demands of our customers and to send you marketing information, product recommendations and other non-transactional communications such as marketing newsletters, telemarketing calls, and texts (SMS/MMS), about us and our affiliates and partners, including information about our products, promotions or events);
• complying with legal obligations (for example when cooperating with public and government authorities, courts or regulators in accordance with our legal obligations under applicable laws to the extent this requires the processing or disclosure of personal data to protect our rights or is necessary to protect against misuse or abuse of our websites, protecting personal property or safety, pursuing remedies available to us and limiting our damages, complying with judicial proceedings, court orders or legal processes or to respond to lawful requests);
• fraud prevention and authentication purposes, and to monitor compliance with our contract and any applicable Platform use requirements and restrictions;
• considering and responding to your job application and other employment or potential employment matters;
• with your consent for any purpose permitted by law and for which you have provided consent;
• use of anonymous data (for example, we may use anonymous, aggregated data for any legal purpose);
• as specifically set forth in any agreement or terms of service we have with you; or
• for those other purposes which may be permitted by applicable law.

Requests for Information. If you provided us with your email address or phone number to receive information from us, we and our fulfillment partners may contact you using the contact information you provided us regarding our Platform and services, such as offers, support and product updates. Pragmatica and our fulfillment partners may make such contact by email, phone and/or text (SMS/MMS), including the phone number you provide us, and we may use automated dialers technology in order to more efficiently connect you with one of our representatives. Your mobile phone carrier’s standard message and data rates may apply to text messages. You are not required to provide your phone number as a condition of purchasing access to our Platform or services, and you can opt out of text messages at any time as described in the “Unsubscribe” section found below within this Policy.

Email and SMS. We may communicate with you through email and text messaging (SMS/MMS) using your personal contact information on file in our systems to inform you of new products, important industry and company news, information about our Platform and services, and as otherwise provided in this Policy, unless you opt out of such communications.

Automated Processing (Including Profiling) and Automated Decision-Making. Automated decision making refers to a decision that is taken solely based on automated processing of your personal data. Profiling is a form of automated processing that involves evaluating and assessing certain aspects about you, in order to analyze or predict your personal preferences, interests, or behavior.

We may use automated decision making and profiling in the following instances:

• Chatbots. We use chatbots, a software that conducts an automated conversation to answer your questions and improve our customer service.
• Analytics. We use automated analytics of your profile and usage experience, based on which we provide personalized product recommendations to you.
• Retargeting. We or our third-party service providers use “retargeting”, which means we may send you or display to you communications and content specifically tailored to your interests and needs based on your previous internet actions.

You may have the right to object at any time to the use of automated decision making or profiling. Please see Your Rights & Choices section below for more information about your rights. To turn off personalized advertising, please change your cookie settings.

We may also use personal data as set forth in the Summary of Data Use, Collection, and Disclosure section of this Policy.

Disclosure of Your Personal Data

General. We may disclose your personal data to our independent contractors, business partners, processors, or service providers who have agreed to (i) hold this information in confidence, and (ii) not use it for any purpose except to carry out the services they are providing for Pragmatica. Such vendors may include providing services enabling us to use personal data as described in the Policy, such as hosting our Platform, services or other data; managing the functionality of our Platform or services; hosting customer relationship management, marketing automation, customer service and other software platforms on our behalf; processing and facilitating payment card transactions and related authentication, security and fraud prevention activities; collecting delinquent accounts; fulfilling and processing orders; delivering products or services you have ordered; conducting background checks and other pre-employment screening; assisting with marketing and promotions; and enabling us to send you email.

We may also disclose your personal data (i) to the extent required by law or if we have a good-faith belief that such disclosure is necessary in order to comply with official investigations or legal proceedings initiated by governmental and/or law enforcement officials, or private parties, including but not limited to: in response to subpoenas, search warrants, or court orders or if we have a good-faith belief that we need to disclose it in order to comply with official investigations or legal proceedings; (ii) if we sell or transfer all or a portion of our company's business interests, assets, or both, or in connection with a corporate merger, consolidation, restructuring, or other company change, (iii) for interest based advertising purposes as described in the Privacy Policy Highlights of this Policy and as more fully described in Do Not Sell My Personal Information – California Privacy Rights; or (iv) as otherwise disclosed in the terms and conditions of our agreements with customers, including our separately posted and applicable Terms of Service for the Platform and other relevant services.

Pragmatica has a number of partner programs designed to maximize our customers' ability to use our Platform and to purchase complementary products and services that may be used in tandem with our Platform. We may disclose information collected from a customer to one or more trusted partners for the purpose of such partner(s) providing assistance and for the purpose of marketing complementary or value-add products and services. In each case such trusted partner will have agreed to (i) hold this information in confidence, and (ii) not use it for any purpose except for the purposes described above. We may disclose your personal data to our subsidiaries or affiliates, but only if necessary for business purposes and legal bases as described in this Policy.

Disclosures of Aggregate or Anonymous Information. Pragmatica may also disclose aggregate, anonymous data based on information collected from you for any legal purpose, which may include analyzing usage trends or seeking compatible advertisers, sponsors, and customers.

Disclosures Made by You. If you use a bulletin board, blog, comment or discussion forum or chat room we make available, or connect with social media, you should be aware that any personal data you submit there can be read, collected, or used by other users of these forums, could be used to send you unsolicited messages, and could be potentially searchable through search engines. We are not responsible for the potential misuse by third parties of any personal data that you choose to submit in these various forums.

We may also disclose personal data as described in the Summary of Data Use, Collection, and Disclosure section of this Policy.

Data Retention

When the purposes of processing are satisfied, we will delete or depersonalize your personal data within a reasonable time period.

Data Integrity and Security

We have implemented and will maintain technical, administrative, and physical measures that are reasonably designed to help protect personal data from unauthorized processing, including unauthorized access, disclosure, alteration, or destruction. Although Pragmatica will use reasonable efforts to secure our systems, we cannot guarantee that the information submitted to, maintained on, or transmitted from our systems will be completely secure. In addition, if we have to disclose your personal data to governmental/law enforcement officials, we may not be able to ensure that those officials will maintain the privacy and security of your personal data.

International Transfers of Personal Data

Your personal data may be collected, transferred to and stored by us in the United States and by our affiliates and third parties that are based in other countries. Therefore, your personal data may be processed outside your jurisdiction, and in countries that are not subject to an adequacy decision by the European Commission or your local legislature and/or regulator, and that may not provide for the same level of data protection as your jurisdiction. We ensure that the recipient of your personal data offers an adequate level of protection, for instance by entering into the appropriate data protection agreements and, if required, standard contractual clauses for the transfer of personal data, as approved by the European Commission, or transfers on the basis of any other data export mechanism authorized pursuant to applicable data protection laws.

Your Rights & Choices

You may have certain rights relating to your personal data, subject to local data protection laws. Please note that you can only exercise these rights with respect to personal data that we process about you when we act as a data controller. This is when Pragmatica decides why and how your personal data will be processed, rather than our customers making those decisions. To exercise your rights with respect to information processed by us on behalf of one of our customers, please read the privacy notice of our customer. Depending on the applicable laws and, in particular, if you are located in the European Economic Area or the State of California in the United States, these rights may include:

For European Economic Area residents:

• To access your personal data held by us (right to access);
• To rectify inaccurate personal data and, taking into account the purpose of processing the personal data, ensure it is complete (right to rectification);
• To erase/delete your personal data, to the extent permitted by applicable data protection laws (right to erasure; right to be forgotten);
• To restrict our processing of your personal data, to the extent permitted by law (right to restriction of processing);
• To transfer your personal data to another controller, to the extent possible (right to data portability);
• To object to any processing of your personal data carried out on the basis of our legitimate interests (right to object). Where we process your personal data for direct marketing purposes or share it with third parties for their own direct marketing purposes, you can exercise your right to object at any time to such processing without having to provide any specific reason for such objection;
• Not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects; and
• To the extent we base the collection, processing and sharing of your personal data on your consent, to withdraw your consent at any time, without affecting the lawfulness of the processing based on such consent before its withdrawal. If you have given consent for your details to be shared with a third party, and wish to withdraw this consent, please also contact the relevant third party in order to change your preferences.

For State of California, United States of America, residents and households:

• You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
• The categories of personal information we collected about you and the categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• You have the right to request that we delete any of your personal information we collected from you and retained, subject to certain exceptions provided by law. Once we receive and confirm your request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We try to acknowledge all requests within ten (10) days and respond to all legitimate requests within one month. We will contact you if we need additional information from you in order to honor your request. Occasionally it may take us longer than a month, taking into account the complexity and number of requests we receive.

You will need to provide us with sufficient information or proof that allows us to reasonably verify you are the person about whom we collected personal data or that the person about whom we collected personal data gave you the necessary and valid signed permission to submit a request on their behalf. Generally, we will request only information that we may have about you to confirm your identity, but under some circumstances we may require additional information or documentation to complete your request. When we receive requests from your agent, we can ask you to verify your identity with us or directly confirm with us that you provided the agent permission to submit the request unless your agent provides us with a valid power of attorney. We cannot respond to your request or provide you with personal data if we cannot verify your identity or authority to make the request. Making a request does not require you to create an account with us. Unless otherwise permitted or required by applicable law, we will only use information provided in a request to verify your identity or authority to make the request.

We generally do not charge a fee to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded, and permitted by law. If we determine that the request warrants a fee and such fee is permitted by law, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination. We will not discriminate against you for exercising any right afforded to you by any data protection law. Unless otherwise permitted by law, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Other Requests. You may ask us to remove content or information that you have posted to our websites. Please note that while we will make reasonable efforts to accommodate such requests, your request does not ensure complete or comprehensive removal of the content or information, because, for example, some of your content may have been reposted by another visitor or third-party.

European Union Supervisory Authority Oversight. If you are a data subject whose personal data we process, you may also have the right to lodge a complaint with a data protection regulator in one or more of the European Union member states.

Our Customers. As described above, we may also process personal data submitted by or for a customer of ours in our capacity of a processor or service provider. We are not responsible for and have no control over the privacy and data security practices of our customers, which may differ from those set forth in this Policy. If your data has been submitted to us by or on behalf of our customer and you wish to exercise any rights you may have under applicable data protection laws, please inquire with the applicable customer directly. Because we may only act upon instruction from that customer, if you wish to make your request directly to us, please provide to us the name of our customer who submitted your data to us. We will refer your request to that customer, and will support them as needed in responding to your request within a reasonable timeframe.

How To Contact Us

General. If you have any questions or concerns about this Policy or the way your information is being used by Pragmatica, you can contact us (i) by email directed to hello@pragmati.ca  If you have a disability you may also contact us to access this Policy in an alternative format.

Other Information

Changes and Effective Date. We may change this Policy at any time and from time to time. The most recent version of the Policy is reflected by the version date located at the top of this Policy. All updates and amendments are effective immediately upon notice, which we may give by any means, including, but not limited to, by posting a revised version or other notice on our website. We encourage you to review this Policy often to stay informed of changes that may affect you. If you would like to see an earlier version of this Policy, please contact us using one of the methods set forth above and specify the applicable date or time period for the prior Policy version requested.

Contract Terms. You consent to our collection, use, and disclosure of your information as described in this Policy. For the purposes of our Policy, when we refer to "you" or to a "customer" we mean any past, current or prospective customer of Pragmatica, and any individual whose personal data is obtained pursuant to this Policy. By choosing to visit and interact with Pragmatica, you agree to comply with the terms of this Policy, and that your visit and any dispute regarding the protection of your privacy during such visit is subject to this Policy and if you are a customer of ours, the dispute resolution provisions in our separate Terms of Services or other agreement applicable to our services. Please note that to the extent a customer enters into other contractual agreements with Pragmatica, the privacy terms and conditions of such agreements (including the separate Terms of Service) may by express reference supplement or supersede portions of this Policy.

‍