Privacy Policy

1. OUR BUSINESS, TECHNOLOGY, CUSTOMERS AND END-USERS

We value your privacy, and we want to help make your experience with us as satisfying and safe as possible, whether you are accessing Viafoura the use of any of our Social Plugins and/or our website available at viafoura.com, including the internal administration system provided to our Clients, available at admin.viafoura.com (the “Admin Area”).

Viafoura is a technology company offering a set of web-based social plugins and tools to engage users on third party websites and apps across the internet and mobile (“Social Plugins”). Viafoura Social Plugins enable online businesses (“Clients”) to:

2. PURPOSE OF PRIVACY POLICY AND REGULATORY FRAMEWORK

We have developed this Policy to explain how we handle personal information received from our customers and end-users. This Policy reflects the requirements of The Personal Information Protection and Electronic Documents Act, a federal statute in force throughout Canada. We inform and train staff on privacy policies.

“Personal Information,” as used in this Privacy Policy, is information that allows a person to directly identify an individual, such as a name or email address, and information that we combine directly with such identifying information. This Privacy Policy is incorporated into and is subject to the Viafoura Terms of Service. By using the Viafoura Website or our Services, you expressly consent to the information handling practices described in this Privacy Policy.

3. INFORMATION WE COLLECT

When you visit viafoura.com or a site powered by viafoura technologies, we collect two types of information. Personal information and passive data. Personal information, you will be prompted and will need to consent before we can store it. Passive data is collected as you interact with the site running Viafoura technology.

Personal Information: If you, as an End User, choose to log into a Client’s website or mobile application using an account you have already established with a social networking platform (e.g., Facebook, Twitter) or an email platform (e.g., Gmail, Yahoo! Mail), you give the website (or mobile application) access to certain Personal Information stored on the given social network or email platform. Viafoura, on behalf of our Clients, will collect and store this Personal Information.  Viafoura’s platform specifically receives and stores name, email and customer generated UID for the purposes of identifying the user.

This End User Passed Data may include, but not be limited to, your name, email address, postal address, and demographic information such as age and gender.

Viafoura clients may enable you to post comments and other user-generated content on their websites or mobile applications. The text of these submissions are collected and stored on behalf of our Clients. These submissions are associated with the identity you used to authenticate with the given Social Plugin, and your name and profile picture will be displayed alongside your Comments on the Client’s website or mobile application. You may also opt-in to post this content to your connected social networks.

Passive Data: Like most web-based services, we automatically receive and record information on our system from your browser when you use sites running Viafoura technology. We may use a variety of methods, including “cookies”, to collect this information. We use both session and persistent cookies. The information that we may collect with these automated methods may include, your IP address, cookie information, a unique device or user ID, browser type, system type, the content and pages that you access on the Viafoura clients, the frequency and duration of your, and the “referring URL”. We may also use cookies to store session validators on your hard drive. If we directly combine any information gathered through passive means with Personal Information, we treat the combined information as Personal Information under this Privacy Policy. Otherwise, we use information collected by passive means in aggregated forms.

Please note that any information collected by Viafoura, is subject to that particular Client’s privacy policy, and that Viafoura is merely facilitating the collection, transfer, and storage of the Personal Information in accordance with that privacy policy.

4. HOW WE USE THE INFORMATION

Personal Information: We maintain no rights to use any End User Personal Information transmitted to us on behalf of our Clients through the Viafoura Services or received from the social networks, except to make the Services available to the Client and/or End User. We do not sell any End User Personal Information transmitted to us through the Services or received from the social networks. All Personal Information captured by our Client’s websites or mobile applications is subject to the privacy policies of those websites. You should read and be aware of the terms of service, privacy policy, and privacy practices of the website of any Client utilizing our Services.

Passive Data Collection: This information is used to facilitate delivery of the Service and, in some cases, for internal reports. Additionally, some of the information collected is used in the Client Reports. The Client Reports may contain both passively-collected information and End User Personal Information.

Certain passively-collected information collected by Viafoura is also made available directly to the Client. The Client then has the ability to manually pass the data to third party analytics tools, like Google Analytics and Omniture Site Catalyst, for additional reporting. This data is owned by our Clients and their own third party analytics accounts. We do this only at the request and direction of the Client.

Please note that, as End Users utilizing Viafoura on a Client’s website, that Client may also passively collect data subject to that website’s particular Privacy Policy, including, without limitation, non-Viafoura actions such as purchases and videos watched. You should read and be aware of the terms of service, privacy policy, and privacy practices of the website of any Client utilizing our Services.

We may share aggregated information with Clients, prospective Clients, partners or the press in order to demonstrate usage of the Service, spot industry and advertising trends, and to generate publicity for the Service. Any aggregated information shared in these contexts will not contain Personal Information.

5. MINORS

The Children’s Online Privacy Protection Act (“COPPA”) protects the online privacy of children under 13 years of age. Viafoura’s Website is not directed toward individuals under the age of thirteen (13), and we request that such individuals do not provide personally identifying information through our websites. Additionally, we do not knowingly collect or maintain Personal Information from anyone under the age of 13, unless or except as permitted by law. If we learn that Personal Information has been collected from a user under 13 years of age on or through the Viafoura Website, then we will take the appropriate steps to cause this information to be deleted. If you are the parent or legal guardian of a child under 13 who has registered on the Viafoura Website or you believe has otherwise provided Personal Information to Viafoura, please contact Viafoura at privacy@viafoura.com to have that child’s account terminated and information deleted.

Viafoura’s clients are responsible for ensuring that they are in compliance with COPPA, Viafoura is merely acting at the direction of our Clients and as an agent of our Clients. If we learn that Personal Information has been collected from a user under 13 years of age through the Viafoura Services without parental consent as required by COPPA and is stored on Viafoura servers, then we will take the appropriate steps to cause this information to be deleted.

6. THIRD PARTIES

We share your information with third parties only in limited circumstances where we believe such sharing is reasonably necessary to offer the service or permitted by you as specified in this Privacy Policy. For example:

We may provide information to service providers to help us bring you the services we offer. Specifically, we may use third parties to facilitate our business, such as to host the service (i.e a cloud web hosting), to send out email notifications or to provide analytics services to our Clients. In connection with these offerings and business operations, our service providers may have access to your personal information for use for a limited time in connection with these business activities. Where we utilize third parties for the processing of any personal information, we implement reasonable contractual and technical protections limiting the use of that information to the Viafoura specified purposes.

We may use pseudonymized and encrypted user identifier information to show ads that are more relevant to our audiences. Further details on how this data is used by third parties such as Google, and how you can control the information that is collected by Google, can be found at the following link: http://www.google.com/intl/en/policies/privacy/partners/.

When you use our website or our products on publishers sites and enter your email address (either to log in, or to sign up for a newsletter, or similar), we may share with LiveRamp and its group companies information that we collect from you, such as your email (in hashed, pseudonymous form), IP address, or information about your browser or operating system, with any of the following, acting as “joint controllers” (as applicable and defined in the GDPR).

LiveRamp uses this information to create an online identification code that we may store in our first-party cookie for our use in online, in-app, and cross-channel advertising. This may be shared with advertising companies to enable interest-based and targeted advertising. LiveRamp uses this information to create an online identification code for the purpose of recognising you on your devices. This code does not contain any of your directly identifiable personal data and will not be used by LiveRamp to re-identify you.

Detailed information on LiveRamp’s data processing activities is available in LiveRamp’s privacy policy. You have the right to withdraw your consent or opt-out to the processing of your personal data at any time.

7. SECURITY

The security of your information is important to us. We use reasonable security measures to protect against the loss, misuse, and alteration of Personal Information under our control, both during the transmission and once we receive it. This includes, but is not limited to, the use of firewalls and encryption. Although we make good faith efforts to maintain the security of such Personal Information, no method of transmission over the Internet or method of electronic storage, is 100% secure and we cannot guarantee that it will remain free from unauthorized access, use, disclosure, or alteration. Further, while we work hard to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent “hackers” or other unauthorized persons from illegally accessing or obtaining this information.

8. CONTACT PERSON ON PRIVACY ISSUES INCLUDING DATA DELETION REQUESTS

9. TRANSPARENCY AND CONSENT COMPLIANCE