Scalable HR Inc, dba ScalableHR^TM (“ScalableHR”, “we” or “us”), and its subsidiaries are committed to safeguarding the privacy of Clients and visitors. This Privacy Policy describes the personal information we collect about you as a visitor to our Website(s) and how we use it, with whom we share it, and describes your choices regarding certain types of processing. If you have any questions regarding this Privacy Policy, contact info@scalablehr.ca or see the “Contact Us” section later in this statement.

By visiting our Website(s) or providing us with your personal information, you consent to the collection, processing, and storage of your personal information as described in this Privacy Policy.

Information Collected
ScalableHR may collect, process, and retain information about you when you visit our Website(s). You may choose to provide us with information, such as your name, email address, company information, street address, telephone number, or other information, to access protected information on our Website(s) or so we can follow up with you after your visit. We may combine other publicly available information related to the organization from which you work for with the information that you provide to us. ScalableHR service providers may observe your activities, interactions, preferences, transactional information, and other computer and connection information (such as IP address) relating to your use of our Website(s) and our services. We may also use log files, cookies and similar technologies to collect information about the pages you view, links you click on, and other actions you may take when accessing our Website(s), services, or emails. For more information about our use of these technologies and how to control them, see our Cookies and Similar Technologies section below. We may collect and store this information and combine this information with other personal information you may have provided.

Client Data
ScalableHR does not share or distribute any Client data except as may be provided in the Service Agreement between ScalableHR and Client, or as may be required by law.

Children
Our Website(s) contain business-related content and are specifically aimed at and designed for use by adults. We do not knowingly solicit or collect personal information from or about individuals under the age permitted in the country where a ScalableHR Client resides.

Use of Your Information
ScalableHR uses the information we collect about you to:

• Provide you with access to the ScalableHR Website(s) and any support you may request.
• Respond to your inquiries or fulfill your requests.
• Diagnose website technical problems.
• Send you information that we believe may be of interest to you, such as product announcements, newsletters, educational materials, and upcoming events.
• Send you administrative information such as notices related to product, service, or policy changes.
• Understand how our ScalableHR Website(s) and services are being used.
• Personalize your experience on our ScalableHR Website(s) and present products or features that are tailored to your interests.
• Prevent, detect, mitigate, and investigate fraudulent or illegal activity.
• As described to you when we collect the information.

Disclosure of Information
ScalableHR does not share, sell, rent, or trade personal information collected through its Website(s) with third parties for their sole promotional purposes or as otherwise outlined in this Privacy Policy. ScalableHR may share information with third-party service providers contracted to provide services on our behalf. These third-party service providers may only use information we provide to them as requested and instructed by ScalableHR. ScalableHR may share information with third parties who resell the ScalableHR service and/or provide value added services.

ScalableHR may offer solely or jointly with third parties, webinars, white paper downloads, or other services related to ScalableHR offerings or services. We may share your contact information and product interest in these offering or services with third parties to communicate with you.

ScalableHR may disclose information in special cases when we have a good faith belief that such action is necessary to: (a) conform to legal requirements or comply with legal process; (b) protect and defend our rights or property; (c) enforce the Service Agreement; (d) act to protect the interests of our users or others, or (e) in connection with a business transition, such as a merger, acquisition by another company, or sale of all or a portion of ScalableHR’s assets.

ScalableHR also may share aggregate or anonymized information with third parties, including advertisers, investors, and partners. Aggregate or anonymized information does not contain any information that can be used to directly identify you and its use and disclosure is not subject to the terms of this Privacy Policy.

International Transfers of Your Information
ScalableHR operates Website(s) in Canada. Depending on your country of residence, the submission of information to our ScalableHR Website(s) may involve the transfer of such information to Canada. When you provide personal information to ScalableHR, you consent to the processing and transfer of your information within Canada. Personal information collected by ScalableHR may be stored and processed in Canada or in any other country where ScalableHR or its subsidiaries, or third-party service providers maintain facilities. Privacy laws in these countries may not provide protections equivalent to those of your country of residence.

The European Union (“EU”) General Data Protection Regulation (Article 44) stipulates that a transfer of personal data to a country outside the EU may take place where the European Commission has decided that the country in question ensures an adequate level of protection and such transfers do not require any specific authorisation. The European Commission has the power to determine, on the basis of Article 45 of Regulation (EU) 2016/679 whether a country outside the EU offers an adequate level of data protection, whether by its domestic legislation or of the international commitments it has entered into. The European Commission has recognized that Canada is providing adequate protection. Directive 95/46/EC of the European Parliament the European Commission confirmed that Canada’s Personal Information Protection and Electronic Documents Act provides adequate protection of the personal data of European citizens. See European Commission’s data protection website for confirmation.

Cookies and Similar Technologies
Cookies are small text files that our ScalableHR Website(s) may ask to place on your computer’s hard drive. If your browser is set to accept cookies, then your browser adds the text in a small file. We do not use cookies to read any other information on your computer’s hard drive. We use cookie technology to authenticate your access to various areas of our ScalableHR Website(s), understand your interests, help analyze web traffic, and tailor content to your preferences. You can configure your browser to refuse cookies, or to warn you before a cookie is placed. If you disable cookies, some parts of our Website(s) may not function properly or at all.

We, and our third-party partners use these technologies to provide certain features on our Website(s), to display advertising based on your web browsing activities, and/or to store content information and preferences. Various browsers may offer their own management tools for removing these technologies.

Choices About Use of Your Information
We believe that it is important to give you choices about the use of your information. We will use your information as described in this Privacy Policy or any service-specific data protection notice. If we want to use your information for a purpose not described in this Policy, we will obtain your consent first.

We will respect your wishes not to receive, or to stop receiving, marketing communications. You can change your marketing preferences by contacting us as described below. If you provided us with your email address to receive such communications, you can opt out at any time by emailing us at info@scalablehr.ca. Please note that we will continue to send you service-related communications regardless of any such request. We will not share or sell your information and personal details with third parties (for the avoidance of doubt, other than subsidiaries) for their own promotional or marketing purposes unless you give us consent to do so and where permitted by applicable law.

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Without a common industry or legal standard for interpreting DNT signals, ScalableHR does not respond to browser DNT signals. We will continue to monitor further development of a DNT standard by the privacy community and industry.

Online Advertising
Some online advertising uses information collected about your web browsing behavior such as the pages you have visited or the searches you have made. This information may be used to display more relevant advertisements and content to you on the ScalableHR Website(s) and non-ScalableHR websites. The information collected is linked to an anonymous cookie ID (alphanumeric number); it does not include any information that could be linked back to a particular person, such as their name, address or credit card number. The information used for targeted advertising may come from ScalableHR or through third-party ad networks.

Third-Party Websites
The ScalableHR Website(s) may contain links to other websites that ScalableHR does not own or control and whose privacy practices may differ from those of ScalableHR. Please be aware that ScalableHR is not responsible for the privacy practices of such other websites. We encourage you to be aware when you leave our ScalableHR Website(s). We recommend that you read the privacy policy of each website that collects personal information, as their privacy policy will govern any personal information you submit to those websites. This Privacy Policy applies only to information collected by the ScalableHR and its subsidiaries Website(s).

Testimonials
We post Client testimonials on our Website(s) that may contain personal information such as the Client’s name. We obtain the Client’s consent prior to posting the testimonial to post their name along with their testimonial. If you wish to request the removal of your testimonial, contact us at info@scalablehr.ca.

Social Media Features and Widgets
Our Website(s) include social media features that may collect your IP address, which page you are visiting on our Website(s), 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 on our ScalableHR Website(s). Your interactions with these features are governed by the privacy policy of the company providing it.

Security
ScalableHR employs industry standard security measures to ensure the security of information. However, the security of information transmitted through the Internet can never be guaranteed. ScalableHR is not responsible for any interception or interruption of any communications through the Internet or for changes to or losses of information. Users of the ScalableHR Website(s) are responsible for maintaining the security of any password, user ID, or other form of authentication involved in obtaining access to password protected or secure areas of any ScalableHR Website(s). To protect you and your information, ScalableHR may suspend your use of a website, without notice, pending an investigation, if any breach of security is suspected. Access to and use of password protected and/or secure area of any ScalableHR Website(s) is restricted to authorized users only. Unauthorized access to such areas is prohibited and may lead to criminal prosecution.

Opt-Out
If at any time after registering for information, your personal information changes or you change your mind about receiving information from us, send us a request specifying updated information or your new choice. Simply send your request to info@scalablehr.ca. Use the same email address if you do not wish to receive our newsletters.

Contact Us
If you have any questions regarding our Privacy Policy or if you need to update, change, or remove information, you can do so by contacting info@scalablehr.ca.

We will retain your information for as long as your account is active or as needed to provide you services. If you wish to cancel your account or request that we no longer use your information to provide you services, contact us via the information above. We will respond to your request to access or delete your information within 30 days. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

If you have any privacy or data use concerns that we have not addressed satisfactorily, please contact info@scalablehr.ca.

Changes to this Privacy Policy
We reserve the right to change or update this Privacy Policy at any time. Changes to the Privacy Policy will be posted on ScalableHR Website(s). We encourage you to periodically review this Privacy Policy for any changes. Your continued use of our Website(s) will signal your acceptance of such changes.

Last Updated: May 13, 2020