PRIVACY POLICY 

Last Modified: September 13, 2021 

Communyco Platform Inc. is a corporation formed pursuant to the Canada Business Corporations Act (R.S.C., 1985, c. C-44). Further to our Terms and Conditions of Use (the “Terms”), this Privacy Policy sets out how we collect, store and use personal information and cookies. Unless otherwise indicated, any capitalized terms in this Privacy Policy have the same meaning attributed to them in our Terms. 

By agreeing to our Terms or by using the Communyco Platform, you consent to the collection and use of personal information in accordance with this Privacy Policy, which we may update from time to time. If you have any questions about our privacy practices, please contact us by email at info@communyco.com

PART I: COLLECTION OF PERSONAL INFORMATION 

The Personal Information of Other Individuals 

To the extent you provide us with or upload data that includes the personal information of another individual, you represent and warrant that you have that individual’s consent to provide us with their information to use in accordance with this Privacy Policy and our Terms. If you do not have their consent, you agree not to upload or provide us with any such personal information. 

To establish an account with us or in connection with your use our Communyco Platform, we (or third-party service providers we use) may collect the following personal information: 

● Full name; 

● Email address; 

● Address (for billing purposes); 

● Banking and/or credit card information for Premium Accounts (once available); ● Your gender, age and location, where you elect to include such information in your profile; 

● Your interests and hobbies or categories of interest to suggest groups or people to connect with; 

● User information from social networking sites, including your name, your social network username, location, gender, birth date, email address, profile picture, and public data for contacts, if you connect your account to such social networks. This information may also include the contact information of anyone you invite to use and/or join the Application; 

● Images (including profile photos), videos, text and audio, where you elect to upload such content in connection with your account; 

● Internet Protocol (“IP”) address, which is logged by servers and which may be associated with a physical location. Your IP address may also be connected to or reveal the details of your internet service provider; 

● We may request access or permission to certain features from your mobile device, including your mobile device’s [bluetooth, calendar, camera, contacts, microphone, reminders, sensors, SMS messages, social media accounts, storage,] and other

features. If you wish to change our access or permissions, you may do so in your device’s settings; 

● Device information such as your mobile device ID number, model, and manufacturer, version of your operating system, phone number, country, location, and any other data you choose to provide; 

● Platform statistics and analytics data regarding your use of the Communyco Platform; ● We may request to send you push notifications regarding your account or the Application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings; 

● Other types of raw data relating to how you interact with the Communyco Platform, for example, your browser information and session duration; 

● All other information you voluntarily provide on the Communyco Platform, or in your correspondence with us. 

Payment Processing 

We may also collect credit card and payment information from you via a third-party payment processor. As of the last date, this Privacy Policy was updated, we use Stripe, Inc. and their related and affiliated entities, with their privacy policy available at https://stripe.com/en-ca/privacy. 

Although we may display their forms on or in connection with the Communyco Platform when you provide your payment details you are providing them to the applicable payment processor. You acknowledge that our third-party payment processors may have their own agreements which apply to you. While we will not have access to your entire credit card number, we will be able to bill your credit card and may have access to the certain card and payment details such as the name on your card, billing address and card expiration date. If you have questions regarding our payment processor, please contact us. 

 

PART II: THE USE OF PERSONAL INFORMATION 

We do not sell your personal information directly to third parties. 

However, we may use personal information to: 

● Facilitate the ordinary operation of the Communyco Platform, for example, displaying your profile and your User Content to other users on the platform; 

● Bill and collect money owed to us; 

● Verify your contact information; 

● Provide user support or to support and improve our Communyco Platform; ● Communicate with you about your account or services we offer; 

● Display informational and promotional materials, including advertisements, from us, our partners, advertisers or third parties to you. We may also customize and tailer advertising to you based on the personal information collected about you, such as your gender, age, location and interests. 

● Send you, via email, informational and promotional materials, including advertisements. You can unsubscribe from promotional materials and advertisements from within your account or by clicking ‘unsubscribe’ links in the emails we send you; ● Pursue available legal remedies to us and to prosecute or defend a court, arbitration or

similar proceeding; 

● To meet legal requirements or seek legal advice from a lawyer in connection with your use of our Communyco Platform; and 

● To enforce compliance with our Terms and applicable laws, rules and regulations. PART III: THE DISCLOSURE OF PERSONAL INFORMATION 

 

Sharing Personal Information and Content if Required by Law 

We may share personal information and any content collected, uploaded or provided to us if required by law, such as in response to a subpoena, court order or other legal processes in any jurisdiction. If we are required by law to make any disclosure of your personal information or content, we may, but are not obligated to, provide you with written notice of such disclosure, if permitted by law. 

Sharing Personal Information to Cooperate with Investigations and Law Enforcement 

Absent a court order, subpoena or other legal requirements to disclose personal information or content in our possession or control, you agree that we may also share personal information and content you upload or which is associated with your account to cooperate with law enforcement authorities in the investigation of any criminal matter if we reasonably believe doing so is necessary or beneficial in protecting your safety, or the safety of any third-party. 

 

Sharing Personal Information with Third-Party Providers 

Our suppliers, partners, independent contractors (collectively “Third-Party Providers”) and/or employees, may have access to or be shared personal information to use in connection with one or more of the purposes for which the information was collected. 

Our Third-Party Providers may have access to personal information in providing services to us or providing you with access to the Communyco Platform. We may use a variety of Third-Party Providers in order to host our Communyco Platform and facilitate their ordinary use, including, for example, hosting servers that store personal information. 

As of the last revision date of this Privacy Policy, among others, we use the following Third-Party Providers who may have access to, or store your personal information, by virtue of our use of their services: 

● Our email and data hosting providers include Google LLC together with their affiliated entities worldwide. For more information on their privacy practices please see https://policies.google.com

● Our data hosting providers include Amazon Web Services, Inc. and their affiliated and related entities. For more information on their privacy practices please see https://aws.amazon.com/privacy/?nc1=f_pr; and 

● Our email marketing provider is The Rocket Science Group LLC, a company headquartered in the State of Georgia in the United States, which operates MailChimp. For more information on their privacy practices please see https://mailchimp.com/legal/privacy/.

We also use the following Third-Party Providers for data analytics in connection with your use of our Communyco Platform, including Google LLC together with their affiliated entities worldwide, in order to use Google Analytics. For details, visit https://analytics.google.com/analytics/web/. 

We may update the above list of Third-Party Providers from time to time as the Communyco Platform continues to evolve. Third-Party Providers may have their own agreements and privacy policies on the collection and use of personal information which either we or you provide them. 

Your Personal Information May Not Be Stored in Canada 

As we may have servers, Third-Party Providers, employees and other parties we share your personal information within locations both inside and outside of Canada, your personal information may become subject to foreign laws and foreign legal proceedings. 

 

Sharing Personal Information if Our Business, Communyco Platform is Acquired 

We may share personal information with our successors (if our business, the Website or Service are acquired by another legal entity) or any assignee of our assets relating to the Communyco Platform. Disclosure in such circumstances is governed by the Personal Information Protection and Electronic Documents Act, SC 2000, c 5 in Canada. 

 

Disclaimer and Warning About Sharing Personal Information Online 

YOU ACKNOWLEDGE THAT WHEN SHARING PERSONAL INFORMATION ONLINE, THERE IS ALWAYS A RISK OF DATA BREACHES, INCLUDING DATA BREACHES IN WHICH THIRD PARTIES UNLAWFULLY ACCESS OUR SYSTEMS, OR THE SYSTEMS OF OUR THIRD-PARTY PROVIDERS, WHICH STORE PERSONAL INFORMATION. 

WHILE WE TAKE MEASURES TO PROTECT PERSONAL INFORMATION, YOU AGREE THAT TO THE FULLEST EXTENT PERMITTED BY LAW, IN NO EVENT WILL WE, OUR AFFILIATES, OFFICERS, DIRECTORS, SHAREHOLDERS, EMPLOYEES, CONTRACTORS, AGENTS, THIRD-PARTY PROVIDERS OR LICENSORS BE LIABLE, HOWSOEVER CAUSED, INCLUDING BY WAY OF NEGLIGENCE, FOR THE LOSS OR THEFT OF YOUR PERSONAL INFORMATION OR ANY DAMAGES CAUSED AS A RESULT THEREOF, SO LONG AS WE WERE NOT DIRECTLY AND GROSSLY NEGLIGENT IN THE PROTECTION OF SAID INFORMATION. 

 

Retention of Your Personal Information 

We keep your personal information for as long as it is required for the purpose for which it was collected. There is no single retention period applicable to the various types of personal information collected. Please contact us if you would like to delete any personal information we hold about you following the termination of your account. 

 

PART IV: Our Use of Cookies

By using our Communyco Platform, you consent to our use of cookies. This cookies policy explains what cookies are, how we use them and how Third-Party Providers may also use cookies on, or in connection with our Communyco Platform. 

What are Cookies? 

Cookies are small text files sent to and automatically downloaded by your web browser (assuming you have cookies enabled) when you visit the Communyco Platform. A cookie file is stored in your web browser and allows our website and Third-Party Providers we use, to recognize you, track your activity across our and other websites and is usually used in conjunction with logging your IP address. 

Cookies can be "persistent" or "session" cookies. Persistent cookies remain on your computer (in your browser files) or mobile device when you go offline, while session cookies are deleted as soon as you close your web browser. 

Can you block the use of Cookies? 

Most web browsers allow you to disable the use of cookies. However, our Website or certain components of our Website may not operate properly, and you may not be able to access and use our Website if you disable cookies. 

How we use Cookies 

Our use of cookies is primarily to analyze how you use our Website, for instance, which pages you visit most often and where you found our Website online. This helps us better understand your user experience and other statistics which we may use to provide a better user experience in future updates to the Communyco Platform. 

For example, cookies are used in connection with our use of Google LLC’s Google Analytics. For more information on Google Analytics and how cookies are used by Google Analytics, see Google LLC’s information page at https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage.