CASHFLOW.IO - PRIVACY POLICY

 

Last Update: October 20th, 2020

 

This Privacy Policy (the “Policy”) contains information about how 10601306 Canada Inc. dba Cashflow.io (referred to as “Cashflow”, “we”, or “us”) collects, uses and discloses your personal information when you are:

• using our public website https://cashflow.io (the “Website”);
• using our cash flow and transactions management platform named Cashflow, which is available as a web application at https://terminal.cashflow.io/, and the associated services (the “Platform”); and
• exchanging with us by e-mails, or social media or otherwise.

(collectively, the “Services”).

This Privacy Policy also covers our use of cookies and other tracking technologies (together, the “cookies”). For the purpose of this Policy, we consider that your cookies are personal information, regardless of applicable laws. The definition of what constitutes personal information is subject to the laws applicable in your jurisdiction, and this Policy shall be interpreted in accordance with applicable laws.

If you have any questions regarding the processing of your personal information, you can e-mail us at privacy@cashflow.io, or reach us by mail at the following address:

Privacy Officer
10601306 Canada Inc.
203-950 Notre-Dame West,
Montréal, Québec
H3C 0K3
CANADA

You can also call us directly: (438) 317-0443

 

1. Key terms

In the Privacy Policy, the term “Platform User” refers to end users who are authorized to use our Platform by our customers with whom we have an agreement.

By comparison, the term “Website User” refers to someone who is navigating our website, or is interacting with us by e-mails, social media or otherwise.

The term “User” or “you” refers instinctively to a Platform User or a Website User. A User can be both a Platform User and a Website User.

 

2. What do we mean by “personal information”?

Personal information is information that relates to a natural person or allows for the identification of a natural person. Some information may not be personal on its own, but may become personal information if associated with personal information or if the sum of the information allows us to identify you. We include cookies in our definition of personal information.

For the purposes of this Privacy Policy, we define personal information as any information which relates to a natural person and allows that person to be identified. For example, this means that we consider electronic identifiers, such as e-mails and passwords, as personal information. You should know that some laws do not include business contact information (ex. name, title, work email, etc.) and other employee personal information in the legal definition of personal information. However, to be transparent with our Users, we included such personal information in our own definition of personal information.

We include cookies in our definition of personal information, although some laws may not consider cookies as personal information. Cookies are messages that web services pass to your web browser when you navigate the Internet. Your browser stores each of these messages in a small file. Cookies can track you across different websites, and serve different purposes. There are various types of cookies: (1) essential; (2) functional; (3) marketing and (4) analytics. Some stay installed only during your session on a website, others are installed for several months or years.

 

3. What types of personal information does Cashflow.io collect, and why?

We collect personal information to provide you with our Services, for the purpose of obtaining analytics on your use of our Services, or in connection with our marketing activities. This section does not cover the cookies that we use.

Category	Description	Justification
Electronic Data	IP address, device type, operating system and Internet browser type, screen resolution, operating system name and version, device manufacturer and model, language, plug-ins, add-ons and language.	This information is collected automatically from Users by our Services to function effectively, to fix bugs, or ensure the security of our Services. We also use this information for analytics purposes to help know more about your use of our Services. These may be collected as part of cookies.
Usage Data	Time spent on the Services, pages visited, links clicked, language preferences, pages that led or referred you to the Website.	This information is collected automatically from Users for analytics purposes.
Communication Data	Name, email address, phone number, employer or owned company,industry of employer or owned company, revenue of employer or owned company, identification data, publicly available information, emails content.	If Users communicate with us by email, through the “Contact” section of our Website, on social media or by any other means, we collect directly from you the personal information that such Users share with us and the content of their communication. If you communicate with us using social media, we will have access to your publicly available information.
Registration Data	First name, last name, title, email address, phone number, title, language preference, username and password. We also ask the name of the company you own or the company you work for.	We collect this information directly from Platform Users to create Platform Users’ accounts on our Platform. We also use your Registration Data to conduct fraud prevention and due diligence, such as to validate your identity. We are required to do this because of applicable laws and to prevent money laundering.We also use your email address to communicate with you about the Platform, such as for updates or maintenance.
Platform User Content	Notes Documents Messages Comments on transactions Feedback on the Platform.	Platform Users can upload documents, notes and comments on the Platform as part of its management capabilities (such as comments they may attach to a specific transaction). To offer these functionalities, we collect the information that you decide to provide through the Platform. To improve our Platform, we also collect the comments Platform Users voluntarily submit through the Platform. We act as a service provider to Platform Users and are not responsible for Platform Users' collection, upload and use  of their clients’ personal information and their use of such information on the Platform. We recommend you to visit such Platform User’s privacy policy as they are responsible for their privacy practices regarding their clients’ personal information.
Support Data	Full name Email addresses Your company’s name Email content Account information Electronic Data	As part of the Platform, we offer support to Platform Users and collect from them the personal information included in your inquiries, as well as the personal information required to identify you and help you resolve the issue.
Social Media	Publicly available information	If you follow us or interact with us on social media, we may process your personal information for marketing or advertising purposes, subject to applicable laws, including those on consent.
Demo Inquiries	Name Email address	If you request a demo on our Website, we ask you to provide us with personal information. You also have the option to include additional information in your request, and we will collect that as well if you choose to do so.
Events, tradeshow and training seminars	Business contact information	If we interact with you as part of events or tradeshow, we may collect your business contact information. If you register to our training seminars, we will collect personal information to register you.

 

4. What cookies do you use and why?

We use cookies for our Services to function as intended, to conduct marketing, to provide functionalities on our Platform, to analyze our performance and ensure that our Services are secure. Cookies are also useful to identify bugs and errors. We use both first-party and third-party cookies installed by partners on our Website.

We collect cookies that classify in each of these categories:

Type of cookie	Description
Essential	Essential cookies are necessary to operate the core functions of our Services. These include login cookies, session ID cookies, language cookies as well as security cookies.
Functional	Functional cookies are used to provide you with some functionalities, such as a live chat, and to remember preferences, consents and configurations.
Analytics	Analytics cookies are used to generate aggregated statistical data about traffic and behavior of Users when using our Services. For instance, we can determine how much time Users spend on a page, and how successful our advertisings are. For instance, the cookie named _ga is used by Google Analytics to gather data about your behavior on our Services.

 

5. Do you use Google Analytics? 

Yes we do. Google Analytics is Google’s analytical tool that helps us to understand how Users engage with our Services. It uses a set of cookies to collect information and report site usage statistics without allowing us to identify individual visitors.

 

6. To whom do you disclose my personal information to?

Let’s be clear, we do not sell your personal information to data brokers. However, we do share your personal information with certain types of third parties to provide you with the Services, conduct marketing and as required by the law. We can also share your personal information in the context of a merger and acquisition, as part of bankruptcy procedures or for other corporate requirements.

Category	Explanations
Service Providers	Service providers are used to provide you with some functionalities that are outsourced to third parties.
IT Service Providers	We use IT Service Providers to offer you the Services, such as to host the Services. For instance, we use DigitalOcean to host the Services (click here to jump to their Privacy Policy
Marketing Partners	We use marketing partners to (1) serve your relevant ads; (2) analyze our advertising campaigns performance; (3) manage our leads and (4) provide you with marketing content. All of these activities require the processing of your personal information, including through cookies.
Financial Aggregators and other Integration Partners	Our Platform can be integrated to many payment processing, accounting, financial planification software such as . If you decide to integrate our Platform with third-party application, this may require the sharing of personal information with these third parties. Integration partners are not suppliers of us. You are required to enter into distinct agreements with them and review their privacy policy.
Law enforcement and other authorities	We may receive requests by authorities to access your personal information. We will validate that the request is licit before responding. When possible, we will advise you. We will only share what is strictly required.

We may share your personal information with our financial and legal advisors or auditors if reasonably required, or in the event we would be required to do so to defend our rights and interests.

In the case of a merger or acquisition, sale of assets, corporate reorganization, bankruptcy filing, insolvency procedures or similar circumstances, your personal information would be considered our assets and property. In these circumstances, ownership of the personal information we collected may be transferred or we may have to share some of your personal information to conclude, negotiate or discuss with third parties. We will only share what we are required to share for these specific purposes.

 

7. Where do you store my personal information?

We use Digital Ocean to host our Services and store your personal information. The servers are located in Canada. However, our suppliers and third parties may process your personal information internationally, including in the United States. Some countries may not offer the same level of protection than in Canada for personal information.

 

8.  How long do you retain my personal information?

We retain personal information for as long as necessary to provide you with the Services, to perform our marketing campaigns effectively or as required by applicable laws, whichever is longer. We use both persistent and session cookies. Session cookies are deleted once you close your browser, whereas persistent cookies remain active on your device for some time. For instance, Google Analytics cookies remain installed on your device for 2 years. This allows Google Analytics to track you for analytic purposes, as well as for marketing purposes, and to provide us with aggregated data on your behavior.

 

9. How do you keep my personal information secure?

We strive to implement physical, administrative and technological security features that are proportional to the risks, taking into consideration factors such as the sensitivity of the personal information that we collect.

However, it is important to understand that we cannot guarantee the security of personal information on the Internet, and that you must also take precautions, such as not sharing your credentials with anyone.

 

10.  Can I manage my Cookie preferences?

You can always manage your cookie preferences. However, some functionalities may require cookies in order to perform as expected, or for security purposes. You can control your cookie preferences through your browser. Depending on the browser that you are using, different instructions are applicable. Click on your browser for more information:

• Google Chrome
• Firefox
• Safari
• Internet Explorer
• Opera
• You can also use private/incognito mode with any of the above

 

11.  Do I have any rights over my personal information

Yes! These rights vary depending on where you are located.

You generally have the right to access your personal information and to correct your personal information if inaccurate, in certain circumstances.

If you want to exercise your rights, you can contact us at privacy@cashflow.io. You can also reach out to us by mail at the following address:

Privacy Officer
10601306 Canada Inc.
709-1010 William street
Montréal, Québec
H3C 0K8
CANADA

We will respond to your request within 30 days. If we can’t comply with your request, we will tell you why.

If you are located in Canada, note that the Office of the Privacy Commissioner of Canada drafted this FAQ to help you access your personal information when it is held by a business. You can also contact the Office of the Privacy Commissioner of Canada’s Information Center:

Telephone
9:00 am to 4:00 pm EST
Toll-free: 1-800-282-1376

Mailing address
Office of the Privacy Commissioner
30 Victoria Street
Gatineau, Québec
K1A 1H3
CANADA

You can also use this online form.

If you have any issue with how we collect, use or disclose your personal information, or how we responded to your request, please let us know at privacy@cashflow.com. We will do our best to improve our processes to make certain that it does not happen again. We will also provide you with additional information about our practices if you would like us to do so.

If you are still not satisfied, you can lodge a complaint to the Office of the Privacy Commissioner of Canada using this online form, or to your local privacy regulators.

 

12. Can we change this Policy?

We may need to modify this Privacy Policy to reflect new processing activities, adapt to new laws and regulations or reflect technological changes or corporate changes, such as a result of a merger and acquisition. We may also change this Privacy Policy at our sole discretion. In case of material changes, we will send an email to Platform Users. You can view the date of the latest update at the top of this page, and you can always reach out to us at privacy@cashflow.io, should you have any questions. Your continued use of the Services is deemed an acceptance of this Privacy Policy.