Vayle Full Privacy Notice

Introduction

Vayle Inc. (“Vayle,” “we,” “us,” or “our”) provides data privacy and protection solutions (our “Services”) for Canadian government entities (our “Customers”). We understand that you are aware of and care about your privacy interests, and we take that seriously.

This Privacy Notice describes how we collect, use, disclose and store information that may identify you as an individual (“Personal Information”). It also describes your choices regarding how we use your data and the rights you may have to access and correct your Personal Information. Please note: We primarily provide our Services to other businesses and the majority of the information we collect is information from and about these government user Customers, as part of a government software (“Govtech”) transaction.

We recognize that information privacy is an ongoing responsibility. Therefore, we will update this Privacy Notice as new Personal Information practices and policies are adopted. When changes are made, we will link previous versions on this webpage for easy reference. Should we make material changes to our Privacy Notice, we will notify our Customers via email if we have your email address.

If you have further questions about this Privacy Notice or any other privacy-related matters, please contact us at [email protected]. High-priority privacy matters can be immediately escalated to Vayle’s CEO at [email protected].

Data We Collect About You

This section outlines the types of Personal Information Vayle collects and the purposes for which it is used, depending on how you interact with us.

1. Customers

If you have engaged Vayle to provide services (a “Customer”), we collect your business contact details and other work-related information. This enables us to fulfill service requests, manage your account, issue invoices, and communicate updates about our Terms of Service and other administrative matters. Note: You should never submit personal information unrelated to your work when interacting with Vayle.

2. Registrants

If you have signed up to receive our content, learn more about our services, or participate in events or surveys (a “Registrant”), we collect your contact information and related preferences. You may choose not to register, opt out of future communications, or request deletion of your data at any time by completing [this form].

3. Website Visitors

If you visit one of our websites, including www.vayle.io, (a “Visitor”), we collect technical and usage information via cookies and similar technologies. This helps us analyze website traffic and improve the relevance of our content and marketing. Please refer to our [Cookie Notice] for more details.

4. Communications and Feedback

If you are a Customer or Registrant, we may also retain records of your communications with us, including feedback or support inquiries, to improve our services and respond appropriately.

Personal Information Collected
The table below provides a simplified view of the Personal Information we will collect about you for each of the circumstances mentioned above. Any personal information submitted via public-facing forms hosted by Vayle is collected on behalf of our Customers and governed by their respective privacy policies.

Information We Collect and Process Customer Registrant Visitor
CONTACT DETAILS
Full Name ✓ ✓
Company ✓ ✓
Job Title ✓ ✓
Work Email Address ✓ ✓
Work Telephone Number ✓ ✓
Work Address ✓ ✓
ETITY DETAILS
Entity Name ✓ ✓
Industry/Sector ✓ ✓
Number of Employees ✓ ✓
PRODUCT MONITORING
Login Times ✓
Log Files (i.e. IP Address) (Work)
Pages Accessed ✓
WEBSITE MONITORING
Work Device IP Address ✓ ✓ ✓
Time Visited Website ✓ ✓
Pages Visited by Device ✓ ✓
Files Downloaded by Device ✓ ✓
Website Navigation Path by Device ✓ ✓
Time Spent by Device on Pages ✓ ✓
Referring Websites ✓ ✓

 

Other Legitimate Purposes

We may also use the Personal Information we collect for other legitimate purposes, including:

    1. Compliance with law enforcement, court, and legal or regulatory requirements;
    2. Information system, network, and cybersecurity purposes;
    3. General corporate operations and due diligence; and
    4. Product development and enhancement.

Collection and Use of Children’s Personal Information

We do not knowingly collect or solicit Personal Information from anyone under the age of 13. If you are under 13, please do not attempt to register for our Services or send any Personal Information about yourself to us. If we discover that we have collected Personal Information from a child under the age of 13, we will delete that information as soon as possible. If you believe that a child under 13 may have provided Personal Information to Vayle, please contact us at [email protected].

When you submit personal information through a public-facing form hosted by Vayle (such as an FOI form), that information is collected on behalf of the applicable organization or institution. It is governed by that entity’s privacy notice, and not by Vayle.

Who Do We Share Your Data With

Sale of Personal Your Information
We will not sell your information (including Personal Information) to any third party for monetary consideration.

Information Shared with Vendor Partners
We may share your Personal Information with vendors, consultants, and other service providers to enable the delivery of Services to our Customers. When we share Personal Information with these vendors, we remain responsible for ensuring that such parties process your Personal Information to the standards required by applicable privacy laws. Such vendors are prohibited from using your Personal Information and are required to keep it confidential. Examples of such vendors include Google Analytics, Hubspot and Microsoft; however, information processed to use our software and services should be business contact information only.

Information Shared for Marketing Purposes
From time to time, we may contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, your Personal Information is not transferred to the third party without your express consent.

How Long We Retain Your Data

How long we keep information we collect about you depends on the type of information we are storing. We will only retain your Personal Information for as long as necessary for the purpose for which that data was collected and to the extent required by applicable law. When we no longer need Personal Information, we will delete it from our systems or anonymize it to ensure you cannot be identified.

If you have elected to receive marketing and communications content from us, we will retain information about your preferences for a reasonable timeframe from the last date you expressed interest in our content, products, or services. We retain information collected from cookies and other tracking technologies for a reasonable period of time from the date such information was collected.

Your Data Privacy Rights

Individual data privacy rights and definitions of what is defined as personal information varies, depending on the jurisdiction. Given we process Personal Data in Canada and the United States only, our Privacy Notice has been written to reflect regulatory requirements within those jurisdictions. In some cases, we have chosen to go above and beyond what is required by law to demonstrate our commitment to protecting Personal Information.

The following list provides an overview of your rights concerning Personal Information we process about you:

  1. Right to request access to your Personal Information.
  2. Right to correct, update your Personal Information.
  3. Right to delete your Personal Information we process about you, except when we are required to retain such information to comply with the law or defend legal claims.
  4. Right to object to the processing of your Personal Information, ask us to restrict the processing of your Personal Information.
  5. Right to request portability of your Personal Information.
  6. You have the right to complain to a data protection authority about our collection and use of your Personal Information.

Marketing and Promotional Materials
You can opt-out from receiving content from us, including promotional communications at any time, by using the unsubscribe link in the emails we send by emailing [email protected]. If you have an account for our Services, we will still send you non-promotional communications, like service-related emails.

Cookie Consent Management
You can accept or reject cookies from our websites through our cookie consent management application. You can also do so by adjusting your web browser controls. Withdrawing your consent will not affect the lawfulness of any processing we conducted before your withdrawal, nor will it affect the processing of your Personal Information conducted on the reliance of lawful processing grounds other than consent. Please consult our Cookie Notice for more information about the use of cookies on our website.

Additional Rights Applicable to U.S. Residents

California Residents

  • Third-party Marketing. We don’t share Personal Information with others for their direct marketing purposes without your consent. We’ll update this policy if that ever changes.
  • Do Not Track. We may collect information about your usage and activity through Cookies, as described in our Cookie Notice. Some web browsers or smartphones have the ability to set “Do Not Track” requests to block user activity from being tracked across web pages or devices. Our Websites do not monitor or respond to “Do Not Track” browser signals.

Nevada Residents

  • We do not sell Personal Information about Nevada residents. Nonetheless, if you are a resident of Nevada, and would like to request to opt-out you may contact us at [email protected].

Legal Disclaimer

Nothing in this Privacy Policy restricts our ability to:

  • Comply with applicable laws;
  • Comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons;
  • Cooperate with law enforcement agencies;
  • Exercise or defend legal claims;
  • Detect security incidents and protect against fraudulent or illegal activity and prosecute those responsible for such activity; or
  • Transfer Personal Information as part of a merger or acquisition, dissolution, bankruptcy, or any other transaction in which a third party assumes control of all or part of our business.