PRIVACY AND COOKIE POLICY
Privacy Notice
Group Link Inc. ("Group Link", "we" or "our") is a Canadian technology company and wholly owned subsidiary of Westsphere Systems Inc., providing software, customer administration, transaction management, compliance support, and business network solutions designed to facilitate commercial relationships between businesses, merchants, affiliates, service providers, financial organizations, and their customers.
Group Link understands the importance of keeping your personal information confidential. We have developed a Privacy Policy that explains the types of personal information we collect, how it is used, and the steps we take to ensure that it is handled appropriately.
1. PRIVACY OVERVIEW
1.1. Group Link Inc is committed to respecting and protecting your privacy. This Privacy Policy applies to the Group Link Inc website and governs its data collection, usage and services. This privacy policy also discloses how we collect, protect, use and share information gathered about you in person or on our website.
1.2. This Privacy Notice may be revised from time to time. If we intend to use or disclose personal information for purposes materially different than those described herein, we will make reasonable efforts to notify affected individuals, if necessary, including by revising this Privacy Notice. We urge you to search and review this Privacy Notice frequently to obtain any recent and current Notice changes. Your continued provision of personal information or use of our services following any changes to this Privacy Notice constitutes your acceptance of any such changes. If you are concerned about how your personal information is used, you should contact us as described below.
1.3. Consent and changes to this Privacy Polic. By using this site, you consent to the collection, use and storage of your information by us in the manner described in this Privacy Policy and elsewhere on the site. We reserve the right to make changes to this Privacy Policy from time to time. If this Privacy Policy changes in any way, we will place an updated version on this page. Regularly reviewing this page ensures that you are always aware of what information we collect, how we use it and under what circumstances, if any, we will share it with other parties.
1.4 . The following commitments apply to all our dealings with our prospective, current, and former clients, as well as individuals whose information we collect or process in connection with servicing our clients. This Privacy Notice is part of every product or service agreement. If there is a difference between this Privacy Notice and any agreement, this Notice takes priority.
2. INFORMATION WE COLLECT
2.1 You can use our website without divulging any personally identifiable information including your email address. Our website does not collect personally identifiable information about individuals except when such individuals specifically provide such information on a voluntary basis, such as when registering at our website, requesting product information, or accessing our “application” features. Group Link Inc. uses such information collected to provide the products or services you request, to improve and customize the content you see, and to contact you about special promotions and new products if requested.
2.2. Collecting Personal Information: Group Link will collect most of your personal information directly from when you interact directly with us, you through applications for our products or services and any supporting documentation and information you provide. We also collect your personal information from sources you have identified in your product or service applications with Group Link, including references you have provided, credit bureaus and from third parties or sources that are available to the public.
2.3. The personal information we collect may include:
(a) Identifiers:
Name, address, telephone number, email address, date of birth, driver’s license or province identification card number, business or organization title, signature samples, tax identification number, account numbers, credit card numbers, debit card number, passport number, information on the device you use to interact with us information (e.g., device model and identifiers, browser type, IP address, security cookies), account information like username and password and Information pertaining to business clients will include financial status and details on the owners, management, and directors.
(b) Transaction and Financial Information:
Information related to transactions arising from your relationship with and through us, and from other financial institutions, including point of sale details.
(c) Recordings:
Recordings and/or transcripts of telephone conversations and Video surveillance recordings captured by security cameras.
(d) Other:
Such other information that will be collected with your consent or as permitted or required by law information to allow Group Link to meet legal and regulatory obligations as well as Canada Revenue Agency's reporting requirements.
2.4. Group Link may monitor or record telephone calls between you and our representatives to ensure accuracy and to enhance customer service. If you do not wish to have your call recorded, you have the option to submit the attached the online Consumer Privacy Request or by contacting us in writing.
2.5. Collecting Non-Personal Identifiable Information - In addition to personal information, Group Link Inc may also gather non-personally identifiable information, which may be used by Group Link Inc. Generally, “non-personally identifiable information” means information that is collected through “traffic data” and may entail the use of “cookies,” “IP addresses,” “pixel tags” or other numeric Notices used to identify a computer or monitor how or when a user accesses the site or communications.
3. USE OF PERSONAL AN NON-PERSONAL IDENTIFIABLE INFORMATION
3.1. Group Link will limit the collection of personal information to what we determine we need for the purposes set out following:
(a) to verify your identity;
(b) to evaluate your application, understand your financial position and to assess your eligibility for requested products and services from Group Link;
(c) to set up, administer, service and manage your products or services;
(d) to communicate with you by various methods regarding products and services that may be of interest to you, including products or services offered by third parties (as permitted by law and consistent with any marketing preferences that we offer and that you have registered with us);
(e) to protect you from error, fraud and any other unauthorized or illegal activities;
(f) to maintain business records for legal and regulatory compliance;
(g) to manage your relationship with Group Link, including measuring the quality of customer service;
(h) to analyze Group Link's business results, compile statistics and conduct market research to better manage Group Link's business and to develop new products and services;
(i) to understand our customers and to develop and tailor our products and services;
(j) to comply with tax, legal and regulatory obligations;
(k) to respond to any questions, you may have;
(l) to evaluate and improve our websites and other electronic offerings; and
(m) for Group Link technologists to evaluate cyber security, AI and machine learning and the development of digital software and architecture to data science.
(n) for any other purpose to which you consent or that is permitted under privacy legislation or any other applicable law.
4. SHARING OF YOUR INFORMATION
4.1. Under certain circumstances, and for the purposes set out in this Privacy Notice, your personal information including some or all the categories of information set out under “Collecting Personal Information” is shared or may be shared among Group Link affiliated companies, outside service providers or third parties for the purposes outlined in “Use of Personal Information.
4.2. Under certain circumstances, Group Link may disclose your personal information to third parties, including the following:
(a) Administration:
We may share your personal information with Group Link affiliated companies, outside service providers or third parties that perform administrative and processing services on our behalf.
(b) Business Processes:
Group Link may disclose your personal information to third parties for the protection of our assets (for example, collection of overdue accounts). We may also share your information with third parties as reasonably necessary in connection with audits or for the purposes of detecting and preventing fraud.
(c) Legal and Regulatory:
Group Link may disclose your personal information as necessary to meet legal, regulatory, industry self-regulatory, insurance, audit and security requirements, including any requirements under Canadian and foreign law that are applicable to Group Link and our service providers.
(d) Fraud Detection and Prevention
Group Link may disclose your personal information to Group Link affiliated companies, outside service providers or other third parties in order, to detect instances of potential fraud, and prevent fraud from occurring.
(e) Business Transactions
Group Link may use personal information and disclose it to third parties connected with the evaluation or in the performance of an actual sale, financing, assignment, insuring or any disposals of all or part of Group Link or our business or assets.
Personal information may also be transferred as part of a corporate reorganization or other change in corporate control of Group Link, or affiliated Companies as a whole.
(f) Service Providers
Group Link may share and/or transfer personal information to outside agents or third-party service providers that perform services on our behalf, such as card production, statement preparation, mailing, customer service, marketing, collections, information technology and/or data hosting or processing services. Such outside agents or third-party service providers will be given only the personal information needed to perform those contracted services and we do not authorize such service providers to use or disclose personal information for their own marketing or other purposes.
(g) Other Third Parties
Group Link may share and/or transfer personal information with other third parties as permitted or required by law:
to comply with laws, regulations, subpoena, or court order;
to respond to valid and authorized information requests from domestic and international authorities;
to prevent and detect fraud and suppress financial abuse; and to protect the personal safety of employees, clients or other third parties on Group Link or Affiliate Property.
We also share aggregated information such as insights, trends, or analytics with outside service providers and other third parties to use for their own benefit. These purposes include products and services improvement and supporting our and affiliate business development.
We have contracts in place holding these service providers to the same standards of confidentiality by which we are governed. In some cases, these other companies may be located outside of Canada (such as in the United States) and may be required to disclose information to courts, government authorities, regulators or law enforcement in accordance with applicable law.
5. MARKETING
51. Unless you have opted out, Group Link may share your personal information with Group Link affiliated companies, outside service providers or third parties to enable our affiliates to offer you additional products and services. Unless you have opted out, in addition to the above uses and disclosures, we may use your personal information (such as your contact information, information relating to the transactions on your account and your payment and purchase details) from time to time in order to determine your suitability for and to occasionally offer you additional products or services of the Group Link affiliated companies, outside service providers or third parties of Companies.
5.2. If you no longer want your personal information used or disclosed for these purposes, you may contact us at any time by mail or by phone at the address or telephone number provided in the "Complaints and Questions" section below.
6. CONSENT AND REGISTERING AT OUR WEBSITE
6.1. By applying for a new Group Link product or service and providing us with personal information, we obtain your consent to our collection, use and disclosure of such personal information for the purposes identified or described in this Privacy Notice.
6.2. Subject to legal or contractual restrictions and reasonable notice, you may withdraw your consent to our collection, use and disclosures of personal information at any time. Note that if you withdraw your consent to certain use of your personal information, we may no longer be able to provide you with the products and services you request.
6.3. Note that you may not be permitted to withdraw consent to certain necessary uses and disclosures (for example, where we are legally required to collect, use or disclose your personal information).
When you register at our website, we request your email address, name and ZIP or postal Notice. We do not currently sell our subscribers’ email addresses to third parties. We may share your email address with third parties to deliver information about product promotions, news and other information about our website, products, services or special promotions on our behalf.
7. EMAIL PROMOTIONS
7.1. You may subscribe to our email promotions program by registering on our website. You may unsubscribe or change your email address for email promotions at any time by following the instructions given within each email promotion.
8. CHILDREN
8.1. Group Link Inc does not sell products for purchase by children. If you are under 18, your parents are responsible for approving your use of this site.
9. PRIVACY AND CHANGE OF CONTROL
9.1. In the event Group Link Inc goes through a business transition, such as a merger, being acquired by another company, or selling a portion of its assets, users’ personal information will, in most instances, be part of the assets transferred.
10. LIMITS ON USE, DISCLOSURE, AND RETENTION
10.1. We will only use or disclose personal information for the reasons it was collected and as otherwise identified in this Privacy Notice. Group Link will only keep your personal information for as long as reasonably necessary to fulfill its intended purpose or to satisfy legal requirements.
10.2. We do not sell the names or other personal information of our customers.
11. ACCURACY
11.1. We will keep personal information as accurate, complete and up–to-date as necessary for the identified purposes. You must play an active role in helping us do this by providing prompt notification of any changes to your personal information, such as your address or telephone number. If you find any error in our information about you, please notify us so that we can make the necessary changes. Failure to notify us of changes to your personal information may negatively impact the way we communicate or provide services to you. Where appropriate, we will advise others of any material amendments to your personal information that we may have released to them. If we do not agree to make the changes you request, you may challenge our decision as described in the "Complaints and Enquiries" section below.
12. SAFEGUARDING PERSONAL INFORMATION
12.1. We will protect personal information with safeguards and security measures appropriate to the sensitivity of the personal information. We use physical, electronic and procedural security measures to protect against the unauthorized use, access, modification, destruction, disclosure, loss or theft of your personal information. Only those authorized Group Link employees who require access to your personal information will have access to your personal information and they are aware of the importance of keeping it confidential.
12.2. We carefully select service providers who may have access to your personal information and require that any information we provide to them must be safeguarded and used only for the purpose of providing the service we have requested the company to perform.
13. ACCESS
13.1. When requested in writing, we will tell you what personal information of yours we have, what it is being used for and to whom it has been disclosed. When requested, we will give you access to your personal information. There may be a small charge for us providing this information to you; however, you will be notified of the approximate cost in advance.
13.2. In certain situations, we may not be able to give you access to all of your personal information. These situations include when it is prohibitively costly to provide the information, when access would reveal information about a third party (i.e. joint account), when access would reveal confidential commercial information, when access would threaten the life or security of another individual, when access would reveal information generated in the course of a formal dispute resolution process, or when access would reveal information gathered for purposes related to investigating a breach of an agreement or a contravention of the law. If we are unable to provide you with some of the personal information, we will tell you why.
14. HOW WE USE COOKIES
When you access our website, we, or companies we hire to track how our website is used, may place small data files called “cookies” on your computer.
We send a "session cookie" to your computer when you log in to your account or otherwise use the Group Link Services. This type of cookie helps us to recognize you if you visit multiple pages on our site during the same session, so that we don’t need to ask you for your password on each page. Once you log out or close your browser, this cookie expires and no longer has any effect.
We also use longer-lasting cookies for other purposes such as to display your e-mail address on our sign-in form, so that you don't need to retype the e-mail address each time you log in to your account.
We encode our cookies so that only we can interpret the information stored in them. You are free to decline our cookies if your browser permits but doing so may interfere with your use of our website. We may also collect information about your computer or other access device to mitigate risk and for fraud prevention purposes.
We and our service-providers also use cookies to customize the Group Link services, content and advertising; measure promotional effectiveness and promote trust and safety.
You may encounter cookies from third parties when using the Group Link Services on websites that we do not control (for example, if you view a webpage created by a third party or use an application developed by a third party, there may be a cookie placed by that web page or application).
15. PIXEL TAGS AND COOKIES
We may use an email delivery and marketing company to send emails. Pixel tags and cookies are used in those email messages and at our website to help us measure the effectiveness of our marketing and how visitors use our site. Pixel tags (sometimes also called “clear GIFs”) are small graphic files, invisible to the human eye, which allow websites or other online services to track users. Group Link Inc. and our third-party advertising company uses pixel tags in HTML-enabled email to track whether (and when) the recipient opened the message. The data on your use of our site may be linked to the Personal Information you have chosen to share with us when you register. Most internet browsers automatically accept cookies. However, you can instruct your browser, by editing its options, to stop accepting cookies or prompt you before accepting a cookie from the sites you visit. If you decide not to accept our cookies, your ability to use some features on our site may be impaired. Certain visitors to our site may have previously received targeted promotional materials relative to the site. Group Link Inc. may share site usage information about such visitors with reputable third parties for the purpose of targeting future campaigns and upgrading visitor information used in reporting statistics. Although our marketing company logs the information coming from our site on our behalf, we control how that data may and may not be used.
ENQUIRIES and/or COMPLAINTS
If you have any questions about our Privacy and Cookie Police, you may contact Group Link's Privacy Officer at:
GROUP LINK INC.
Attn: Chief Privacy Officer
#12, 3620 – 29th Street NE
Calgary, Alberta T1Y 5Z8
1.866.206.3301
If you are not satisfied with how your enquiry or complaint has been handled, you may follow Group Link's dispute resolution process by visiting https://www.Group Link.ca/legal/resolving-complaints and review the "Resolving Your Complaint" information.
Finally, if Group Link was unable to adequately address your complaint, concern or question, you may also contact The Office of the Privacy Commissioner of Canada at:
Office of the Privacy Commissioner of Canada
30 Victoria Street
Gatineau, Quebec K1A 1H3
1-800-282-1376