Privacy policy
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GRASSROOTS CONSULTING INC, its parent, subsidiaries and affiliates ("Grassroots", “we”, “us”) respect your privacy. This "Privacy Policy" summarizes what personal information we collect, and how we use and disclose this information of our customers and website users (“you”). Please read this Privacy Policy carefully to understand our policies and practices regarding personal information.

 

By access or using our website: https://www.icsreport.org (our “Website”), subscribing for our content, accessing our content, purchasing and/or using the products/services we provide (collectively, the "Services"), you signify indicate that you understand, accept and consent to the practice and terms of our Privacy Policy. If you do not agree with any terms of this Privacy Policy, please do not use our Website and/or Services or submit any personal information to us. You affirm that if you are accessing or using the Website and/or Services on behalf of an organization or company, reference to you shall also refer to any such organization or company and that same shall be governed by this Privacy Policy.

 

This Privacy Policy applies to information we collect, use, or disclose about you: on this Website and/or Services; in email, text, and other electronic messages between you and this Website and/or Services; and/or when you interact with our advertising and applications on third-party websites and services if those applications or advertising include links to this policy.

 

We reserve the right to modify this Privacy Policy at any time. We will reflect any such modifications to this Privacy Policy on our Website. Your continued use of our Website and/or Services will be regarded as acceptance of our practices around privacy and personal information including but not limited to this Privacy Policy, as revised. You should check this Privacy Policy regularly to review any changes.  

 

What Personal Information We Collect

Personal information is information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person (“Personal Information”). We collect Personal Information when you voluntarily provide it through our Website or when you provide it to us through other means, including but not limited to: email, telephone, mail; or other correspondence; or registering for our Services; and/or entering into any agreements for our Services.

The Personal Information we may collect will depend on the particular Service you request, and may include (but is not limited to) your full name, contact information, such as your address, telephone number, or email address; any other Personal Information that you choose to submit to us, including but not limited to your personal health information. In addition to Personal Information, we may collect non-personal information, that does not directly or indirectly reveal your identity or directly relate to an identifiable individual, such as demographic information, or statistical or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal information. For example, we may aggregate personal information to calculate the percentage of users accessing a specific Website feature. We may also collect technical information, including your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, or information about your internet connection, the equipment you use to access our Website, and usage details.

 

If you access our Website or Services through social media such as Facebook, LinkedIn or Twitter, or other similar websites, we may obtain Personal Information from said accounts. This Privacy Policy does not cover your privacy, use of and/or retention of information on social media accounts which are governed by the privacy policies of the third parties that operate these social networks and therefore Grassroots does not assume responsibility or liability for the manner in which these operators collect, use, disclose, secure or otherwise deal your Personal Information.    

How We Collect Information through Technological Means

When you visit our Website and/or use our Services, we may collect information that is automatically sent to us by your web browser. This information may include your domain name and your IP address. We may also collect other information, such as the type of browser you use, which pages you view, and the files you request.

 

We use this information to better understand how our Website and Services are used and to improve our Website and Services to better meet your needs. The amount of information that is sent by your web browser depends on the browser and settings you use. Please refer to the instructions provided by your browser if you want to learn more about what information it sends to websites you visit, or how you may change or restrict this.

 

We also collect information that is submitted by you. This incudes information that you provide by filling in Grassroots agreements, forms and/or other documents (whether on our Website or otherwise), such as information provided at the time of registering to use our Website or agreeing to our Services or requesting further services. We may also collect information when you report a problem with our Website, search queries on our Website, or otherwise provide information to us. We further collect information from records and copies of your correspondence (including email addresses), if you contact us, and details of transactions you may carry out through our Website and/or Services.

 

You may also provide information (including but not limited to Personal Information) to be published or displayed (hereinafter, "posted") on public areas of the Website/Services or transmitted to other users of the Website/Services or third parties (collectively, "User Contributions"). Your User Contributions are posted on and transmitted to others at your own risk. Although we may limit access to certain pages, please be aware that no security measures are perfect. Additionally, we cannot control the actions of other users of the Website and/or Services with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that unauthorized persons will not view, access or otherwise obtain your User Contributions

 

 

Use of Cookies

“Cookies” are text files placed on your computer, to help the website, software, application or otherwise analyze how users use same. We may use "cookies" and other similar devices on our Website and Services to enhance functionality. These devices may track information which includes but is not limited to: (i) IP address; (ii) how the Website is navigated; (iii) the type of web browser and operating system used; (iv) the content accessed; and (v) the pages of the Website visited. If you wish to disable cookies, refer to your browser help menu to learn how. If you disable cookies, you may be unable to access some features related to the provision of our Website and/or Services.

 

You can opt-out of several third-party ad servers' and networks' cookies simultaneously by using an opt-out tool created by the Digital Advertising Alliance of Canada. You can also access websites to learn more about online behavioural advertising and how to stop websites from placing cookies on your device. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.

 

Advertising networks and third parties that provide advertisements or services on or through the Website may use their own cookies. This Privacy Policy does not cover the use of cookies by third parties. We do not control these third parties' tracking technologies or how they are used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

 

Age of Majority

 

Our Website and Services are not intended for persons under the age of majority. No one under such age may provide any information to or on the Website or use our Services. We do not knowingly collect personal information from children or persons under the age of majority. If you are under the age of majority, do not use or provide any information on this Website or Services, including your name, address, telephone number, email address, or any screen name or user name you may use. 

 

How We Use and Disclose Personal Information

The Personal Information we collect may be used by us for the purposes for which it was collected, as provided in this Privacy Policy, or for other purposes that are disclosed to you and to which you consent. We may use your Personal Information to, without limitation: (i) to present our Website and/or Services and its contents to you and to improve such; (ii) to provide you with information, products, or services that you request from us; (iii) meet legal and regulatory requirements; (iv) track and analyze trends and patterns; (v) to verify your identity if you submit comments, videos, photographs, opinions, or any other content or information to the Website and/or Services; (vi) to respond to questions, comments, surveys, requests, job applications, or complaints that you submit to Grassroots; (vii) create aggregate information that does not allow you to be personally identified; (viii) to improve our customer relationships and experiences; (ix) and/or to communicate information, such as promotions, newsletters, surveys, contests, etc. if you have consented to receive such from Grassroots.

 

We may also use your information to contact you about our own goods and services that may be of interest to you, as permitted by law. If you do not want us to use your information in this way, please check the relevant box located on the form on which we collect your data (the registration form),adjust your user preferences in your account profile, use the unsubscribe mechanism at the bottom of our e-mails and/or e-mail us at icsreport@protonmail.com.

 

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. We may also disclosure Personal Information to: (i) our subsidiaries and affiliates; (ii) in accordance with applicable law, to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Grassroots' assets; (iii) to contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Website/Services improvement and optimization) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the Personal Information with the same standards set out in this policy; (iv) to fulfill the purpose for which you provide it; and (iv) with your consent.

We may also disclose your personal information: (i) to comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law; (ii) to enforce or apply our terms and other agreements; and/or (iii) if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Grassroots, our customers, or others.

 

Where we disclose Personal Information to third parties that perform services on our behalf, we will require those third parties to use such information solely for the purposes of providing services to us and to have appropriate safeguards for the protection of that Personal Information. You may separately agree to provide your Personal Information to third parties that provide content and/or offerings to our Website and/or users. If you agree to provide such information to these third parties, then your Personal Information will be subject to their privacy policies in addition to our own.

 

We may disclose your Personal Information to a third party or parties where you consent to such disclosure or the disclosure is required by law. Some or all of the Personal Information we collect may be stored or processed in jurisdictions outside of Canada, including the United States. As a result, this information may be subject to access requests and legal requirements from governments, courts, law enforcement or regulatory agencies in those jurisdictions according to laws in those jurisdictions. Your submitting of Personal Information or otherwise engaging with our Website and/or Services indicates your consent to such storage and/or processing.

 

We reserve the right to transfer Personal Information in the event that we merge with or are acquired by a third party. We also may disclose your Personal Information for any other purpose permitted by law or to which you consent.

 

 

How We Protect Personal Information

 

We protect your Personal Information by maintaining physical, organizational and technological safeguards appropriate to the sensitivity of such Personal Information. Personal Information may only be accessed by persons within or under contract with our organization and who require such access. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website and/or Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website and/or Services.

We retain Personal Information that we collect only as long as necessary for the purposes for which it was collected or to meet legal requirements. We destroy Personal Information when it is no longer needed. Under some circumstances we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.

 

The Website and Services may provide links to other third-party content. Even if the third party is affiliated with Grassroots, through a business partnership or otherwise, Grassroots is not responsible for the privacy policies or practices or the content of such external links. We do not assume responsibility for the accuracy or appropriateness of the content contained on those websites and/or other services. You enter those sites at your own risk. A link to the same should not be construed to mean that we are affiliated or associated in any way or that we endorse or recommend those websites and/or services. These links are provided to you for convenience purposes only and you access them at your own risk.

 

Access and Rectification

 

You have a right to access to your Personal Information and to request a correction to it if you believe your Personal Information is inaccurate. We will provide you with access to your Personal Information that is in our possession, subject to certain exceptions, including information that is referenced to another individual’s personal information that we cannot sever, or information subject to legal restrictions that may prevent us from fulfilling your request. If you have submitted Personal Information and would like to have access to it, or if you would like to have it corrected, please contact us using the contact information provided below. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

 

We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the Personal Information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the Personal Information that we hold about you, or we may have destroyed, erased, or made your Personal Information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

 

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes. You can review and change your personal information by logging into the Website and visiting your account profile page.

If you delete your User Contributions from the Website and/or Services, copies of your User Contributions may remain viewable in cached and archived pages or might have been copied or stored by other Website/Services users.

 

Transferring Your Personal Information

 

We may transfer Personal Information that we collect or that you provide as described in this Privacy Policy to contractors, service providers, and other third parties we use to support our business. To the extent possible, we will obligate such businesses to use this information only for the purposes for which we disclose it to them and to process the Personal Information with the same standards set out in this policy.

 

To facilitate our operations, we may process, store, and transfer your Personal Information in and to a foreign country, different from that where you live (including the United States of America). Laws in these foreign countries have different privacy laws that may or may not be as comprehensive as Canadian law or the applicable law of your country of residence. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that foreign country may be able to obtain access to your Personal Information through the laws of such country.

 

By submitting your Personal Information or engaging with the Website and/or Services, you consent to this transfer, storage, or processing.

 

Information for Residents of the United Kingdom (UK) and European Union (EU)

Legal Basis for Processing. As described above, our processing (i.e., collection and use) of your Personal Information is based on one of a number of legal conditions. Generally, these include: (i) your consent; (ii) the performance of a contract with you; (iii) compliance with a legal obligation (for example, where we are required to disclose personal information to a court or a tax authority); and (iv) our legitimate interests, provided these do not override your fundamental rights and freedoms (for example, where we carry out research and analysis to improve our Website and Services).

Rights of UK and EU Residents. Subject to applicable law, as a resident of the UK or the EU, you may have certain rights with respect to your Personal Information. These rights may include some of the following:

  • to obtain a copy of your Personal Information together with information about how and on what basis that Personal Information is processed;

  • to rectify inaccurate Personal Information;

  • to erase your Personal Information (in limited circumstances, such as where it is no longer necessary in relation to the purposes for which it was collected or processed);

  • to restrict processing of your Personal Information where: (i) the accuracy of the Personal Information is contested; (ii) the processing is unlawful, but you object to the erasure of the Personal Information; or (iii) we no longer require the Personal Information, but it is still required for the establishment, exercise or defense of a legal claim;

  • to challenge processing which we have justified based on a legitimate interest;

  • to prevent us from sending you direct marketing;

  • to withdraw your consent to our processing of your Personal Information (where that processing is based on your consent); and

  • to obtain or see a copy of the appropriate safeguards under which your Personal Information is transferred to a third country or international organization. 

In addition to the above, you have the right to lodge a complaint with your local supervisory authority, depending on where you have your habitual residence or place of work, or where an alleged infringement of applicable data protection law occurs (for example, the Information Commissioner’s Office in the United Kingdom, contactable at www.ico.org.uk). For the European Economic Area (“EEA”), a list of data protection authorities is available at https://edpb.europa.eu/about-edpb/about-edpb/members_en.

Exercising Your Rights. If you would like to exercise any of the rights described above, please submit a request using the contact details listed below. Please note we will request proof of your identity and verify such identity in order to protect your Personal Information and ensure compliance with all applicable regulations and policies. In some cases, we may limit or deny requests where permitted or required by law. For example, except where disclosure is required by law, we may decide not to grant access or make revisions where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in any given case, or when the rights of others would be violated by granting the access. Additionally, we may deny a request if we are unable to adequately verify your identity. We reserve the right to charge a fee where permitted by law, including for example, if your request is manifestly excessive or unfounded. We will respond to your requests within the applicable timeframes and consistent with applicable regulations.

International Transfers for UK and EU Residents. GRASSROOTS CONSULTING INC is based in Ontario, Canada. As part of the operation of our Website and provision of Services, your Personal Information may be transferred to and stored in the United States for processing. Additionally, any Personal Information that you provide to or that is collected by or on behalf of us may be transferred or accessed by entities around the world consistent with the practices described within this Privacy Policy. The privacy laws in these countries may be less stringent than the laws in your country of residence. In relation to service providers or suppliers, for Personal Information that is transferred outside of the UK and the EEA, we rely on adequate measures such as the EU Commission-approved Standard Contractual Clauses, which give personal data the same protection it has in the UK and the EEA. If we send your Personal Information to Canada it is protected under Canadian law, which the European Commission has found will adequately protect your information. You may have a right to request additional details about the mechanisms under which your data is transferred outside of the UK and the EEA. If you would like more information concerning our attempts to apply the privacy principles applicable in one jurisdiction to data when it goes to another jurisdiction you can contact us using the contact information below.

Withdrawing Consent

 

Where you have provided your consent to the collection, use, and transfer of your Personal Information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us using the contact information below. Please note that if you withdraw your consent, we may not be able to provide you with use or access to our Website or Services.

 

Changes to this Privacy Policy

 

Grassroots reserves the right to modify our Privacy Policy at any time, so please review it from time to time. If we make significant changes to this policy, we will notify you here, by email, or by a notice on our applicable Website, so you continue to be aware of the information we collect, how we use it, and under what circumstances we disclose it.

 

Unsubscribe

 

If you no longer wish to receive electronic messages and/or Services from Grassroots, you may unsubscribe in the “unsubscribe” link in the e-mail you receive (as applicable), follow the instructions in the e-mail you receive, or contact us at the information listed in this Privacy Policy. Please note that, after you unsubscribe, Grassroots may still send electronic communications to you in certain limited circumstances, such as to provide you with Website and/or Services notifications, or to provide information that Grassroots is legally obligated to provide you.

 

How to Contact Us

If you have any questions regarding this Privacy Policy, or to access your information, please contact our Privacy Officer at: icsreport@protonmail.com.