Privacy Policy

Last Updated: November 8, 2018

Introduction

At Permission Click Inc. (“Permission Click”, “we”, or “us”), your privacy is important to us. We are committed to protecting your privacy when managing your Personal Information (as that term is defined below).

This Privacy Policy is designed to help you understand how Permission Click Inc. collects, uses and discloses Personal Information when individuals use the permissionclick.com, and permissionclick.com.au (the “Websites”) as well as our software services more particularly described in our Terms of Use (the “Services”). By using the Websites or any Services, you are accepting the practices described in this Privacy Policy. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT USE THE WEBSITES OR SERVICES.

We have policies and procedures to ensure that all Personal Information is handled carefully and securely in accordance with applicable privacy laws.

The purpose of this Privacy Policy is to tell you:

  • what kind of Personal Information we may gather about you;
  • how we may use that Personal Information and the choices you have regarding our use of such information;
  • whether we disclose your Personal Information to anyone;
  • how you may enquire, access and/or seek correction of your Personal Information and our access and correction handling procedure; and
  • how you may alert us about an alleged breach of the applicable privacy laws and our complaint handling procedure.
Collection of Information

Personal Information

In this Privacy Policy, “Personal Information” refers to any information about an identifiable individual and any information that is linked to an identifiable individual.

The type of Personal Information collected will be directly related to the specified purpose it has been collected for. How much of your Personal Information that you choose to disclose to us is completely up to you. The only way we know something about you personally is if you provide it to us. However, failure to provide certain information may result in Permission Click being unable to provide you with the relevant Service. We will make you aware of the purpose for which we collect the Personal Information and, where possible, the consequences of not providing it at the time of collection.

Our primary purpose in collecting information is to provide you with a safe, secure online application which will assist you in sharing information and forms to communicate with other people and organizations, or to create new content. In particular we collect Personal Information in the following ways:

  • Many of our Services require you to sign up for a Permission Click account. When you do, we will ask for Personal Information such as your name and contact details including email address, phone number(s), billing and/or postal address, your credit card or other payment details and usually the school, club or business which you are utilizing via your Permission Click account. You will also have the option of providing additional information to personalize your account, such as a profile picture.
  • If a user creates forms through our Services and arrange for them to be sent to recipients, they provide information like name and email address of the recipients. When users want additional assurances about the identity of the individual signing their forms or contracts, they may require us to collect some additional information that we use to authenticate recipients before they are able to sign a form or contract.
  • If you use the Services as a recipient, Permission Click will collect any Personal Information you enter into the form, including Personal Information about your children or other third parties.
  • If you make an enquiry, provide feedback or make a complaint to us, we may collect your name and contact details.
  • If you choose to comment on our blogs or in our community forums or otherwise volunteer information, you provide us with that information and it may be available to other users and even the public. This means that it can be read, collected and used by others without our knowledge, including to send unsolicited communications.
  • If you use our referral service to tell a friend about our services, you will provide a friend’s name and email address. We will then send a one-time email to the address provided, inviting the friend to try the services. We will store this Personal Information for the purposes of sending this email and tracking the success of our referral program. That person would be able to unsubscribe at any time. We may disclose to that person or entity that you were the source of their information.
  • If you participate in any surveys we, or a third-party service provider acting on our behalf, may conduct from time to time, we may collect Personal Information relating to your survey responses.

You acknowledge that the Personal Information we collect from you is your own information or information which you have been authorized to provide us.

Sensitive information

Permission Click does not generally collect sensitive information as defined under the Privacy Act, such as racial or ethnicity information, political opinions or associations, criminal records or health information. However, if you are using the Services in connection with an organization that has a religious or other similar affiliation, the fact that you are affiliated with such organization will be collected.

Unsolicited information

Where unsolicited information is received by Permission Click (such as through any Facebook page or other social media platforms we operate or may establish) we will determine, within a reasonable period of time, whether or not we would be permitted to collect the information under the applicable privacy laws. If it would not be permitted for Permission Click to collect the Personal Information, we will destroy the Personal Information or ensure it is de-identified as soon as practicable. Otherwise, Permission Click may retain the Personal Information in accordance with the terms of this Privacy Policy.

Information we collect automatically

When you visit our Website(s) we may collect certain information by automated means such as through the use of cookies, other automated devices and website tracking tools such as Google Analytics. We use Google Analytics to collect information about how our Website(s) are used. Google Analytics generates statistical and other information about websites by means of cookies stored on users’ computers. Google may collect, transfer, store, and process this information on its servers located in the United States. We will not use Google Analytics to track or collect any Personal Information from visitors to our Website(s). You can read about how Google Analytics collects and processes data at How Google uses data when you use our partners’ sites or apps. If you do not want information relating to your visit to our Website(s) reported by Google Analytics, you can install the Google Analytics opt-out browser add-on. For more information see Google Analytics Opt-out Browser Add-on.

The type of information we may collect by automated means includes:

  • your visiting domain name or IP address;
  • the device, browser, operating system type and screen resolution you use;
  • information on actions taken at our Website(s) such as navigation patterns (i.e. pages viewed and downloaded; products viewed and/or purchased) and the date, time, duration and number of times you visited our Website(s);
  • the previous site you visited;
  • the geographical location (such as the country and city of origin) from where you accessed our Website(s); and
  • the website you came from (if any), search terms or any other webpages that led you to our Website(s).

Other third parties, including Facebook, may use cookies, web beacons, and other storage technologies to collect or receive Personal Information from the Websites and elsewhere on the internet and use that information to provide measurement services and targeted ads. Note that Permission Click does not provide any interest-based advertising or create advertising profiles of users. Users can update their advertising preferences and limit cookies used by their browsers and third parties by updating settings at: http://www.aboutads.info/choices and http://www.youronlinechoices.eu.

You can also change the privacy settings of your browser to refuse all cookies or to notify you each time a cookie is sent to your computer. However, by blocking or deleting cookies used for our Website(s), you may not be able to take full advantage of services offered via our Website(s). This is because cookies are used to help you navigate the Website(s) and to perform certain functions when using our Website(s) such as delivering content specific information to you.

The information we collect automatically is also used for statistical and administrative purposes (e.g. the number of visits by visitors to our Website). Analyzing the way in which visitors utilize our Website(s) enables us to improve our services. The information is not used in any way to uniquely identify a customer and we do not collect information about the identity of the visitors unless they voluntarily provide that information. Visitors or their browsing activities (other than previously stated) will not be identified except in the event that any law requires us to disclose or permit a law enforcement agency to inspect the service provider’s logs.

Method of collection

This Personal Information will only be collected through lawful and fair means and not in an unreasonably intrusive way.

Permission Click collects your Personal Information when you deal with us directly, including via our Website(s) or our Facebook, Instagram or other social media platforms we operate or may establish, via forms or correspondence (i.e. by mail or email), over the phone or in person.

Create and Send Forms

When users create forms through our Services and arrange for them to be sent to recipients, they provide Personal Information such as name and email address of the recipients. When users want additional assurances about the identity of the individual signing their forms or contracts, they may require us to collect some additional information that we use to authenticate recipients before they are able to sign a form or contract.

Social Media

When you use a social media account to sign in to the Services, you provide us with the user ID associated with any social media account (e.g., Google) that you use. If you sign in with or otherwise connect your social media account to the Services, you authorize us to collect, store, and use in accordance with this Privacy Policy any and all information available to us through the social media interface, including without limitation any information that you have made public in connection with your social media account, information that the social media service shares with us, or information that is disclosed as being shared during the sign-in process. Please see your social media provider’s privacy policy and help center for more information about how they share information when you choose to connect your account.

Referral

When users use our referral service to tell a friend about our Services, they will provide a friend’s name and email address. We will send a one-time email to the address provided, inviting the friend to try the Services. Permission Click stores this information for the purposes of sending this email and tracking the success of our referral program. The individuals who receive these messages can follow the instructions for unsubscribing in the message or contact us at the email address (privacy@permissionclick.com) to request that we remove this information from our database.

Use of information

Use of Personal Information

Permission Click will use the Personal Information you have chosen to provide us for the purpose for which you provided it. Permission Click will not use it for any other purpose without your consent, unless permitted or required by law.

Generally, we will use your Personal Information for the following purposes:

  • to facilitate the transaction and online services that you are engaged in with Permission Click or a third party such as a school, club or business which you’re associated with;
  • providing the Services you have requested from Permission Click;
  • to respond to any enquiries, feedback or complaints made by you;
  • to provide, maintain, protect, and improve these services, to develop new services, and to protect Permission Click and our users;
  • we may present your name, email address or photo to other users in your organization or otherwise associated with your Permission Click account in order to assist in sharing or making recommendations;
  • we may use the name you provide for your Permission Click profile across all of the services we offer that require a Permission Click account. In addition, we may replace past names associated with your Permission Click account so that you are represented consistently across all our Services. If other users already have your email, or other information that identifies you, we may show them your publicly visible Permission Click profile information, such as your name and photo;
  • if you use Permission Click to send documents, we will encrypt and store these documents in an account and make the contents available only to those whom you invite to view or sign these files. We restrict our employees’ access to this information so that their access is only as reasonably necessary for us to provide services;
  • when you contact Permission Click, we may keep a record of your communication to help solve any issues you might be facing. We may use your email address to inform you about our services, such as letting you know about upcoming changes or improvements. If you send us personal correspondence, such as emails or requests for demos, we may collect Personal Information, such as name, email address and phone number, into a file specific to you;
  • if you register for Permission Click on another website or use a website providing a service for Permission Click or a website that helps facilitate your activity on Permission Click, that website may provide Personal Information about you and your transactions back to Permission Click; and
  • We may combine information from one service, including Personal Information, into other Permission Click Services, for example to make it easier to share things with people you know.

We may aggregate and/or de-identify the information we collect to limit or prevent identification of any particular user or device. Our use and disclosure of aggregated and/or de-identified information is not subject to any restrictions under this Privacy Policy, and we may disclose it to others without limitation for any purpose.

We will ask for your consent before using information for a purpose other than those that are set out in this Privacy Policy.

Direct marketing

Permission Click will only use customer Personal Information for the purpose of direct marketing activities to our customers (schools, school districts and other organizations) where we have obtained your consent to do so, or in circumstances where we have collected the information directly from you and you would reasonably expect that your Personal Information would be used or disclosed for this purpose. We may also share customer Personal Information with related entities of Permission Click, so that they can provide you directly with marketing material about their products and services (subject to obtaining your prior consent if the entity is not a related body corporate). Any direct marketing materials that you receive from us via email may utilize open tracking so that we can monitor delivery and receipt of the material. For greater certainty, Permission Click does not send any direct marketing to students or parents of students.

Permission Click will provide you with the opportunity to opt out of receiving marketing materials at the time of collection and/or at any time afterwards by either unsubscribing from the email service or contacting our Privacy Officer via the contact details provided below.

Use of information collected automatically

In addition to the uses described above, Permission Click uses information collected automatically to:

  • monitor the use of our Website(s);
  • help us make improvements to the Website(s); and
  • offer relevant information and services to as many users as possible.
Disclosure

With account administrators

If your Permission Click account is managed for you by an organization administrator, then your organization’s administrator and resellers who provide user support to your organization will have access to your Permission Click information (including your email and other Personal Information) in order to:

  • View statistics regarding your account;
  • Change your account password;
  • Suspend or terminate your account access;
  • Access or retain information stored as part of your account;
  • Receive your account information in order to satisfy applicable law, regulation, legal process or enforceable governmental request;
  • Restrict your ability to delete or edit information.

Please refer to your account administrator’s privacy policy for more information.

Disclosure to Third Parties

There will be occasions where it will be necessary for Permission Click to disclose your Personal Information to third parties.

Permission Click may disclose your Personal Information:

Under no circumstances will Permission Click sell or receive payment for licensing or disclosing your Personal Information.

With Affiliates

We may share your information with other companies under common ownership or control with Permission Click.

If Permission Click is involved in a merger, acquisition or asset sale, Permission Click may disclose Personal Information to an acquiring entity in accordance with applicable privacy laws. Personal Information may be governed by the acquiring entity after the transaction is complete. However, as part of the Student Privacy Pledge, any acquiring company must promise to abide by the Student Privacy Pledge commitments.

International Transfers of Personal Information

Permission Click is a global business and, unless otherwise indicated, Personal Information may be stored and processed in any country where we have operations or where we engage service providers. We may transfer Personal Information that we maintain about you to recipients in countries other than the country in which the Personal Information was originally collected, including to Canada and the United States. Those countries may have data protection rules that are different from those of your country. However, we will take measures to ensure that any such transfers comply with applicable data protection laws and that your Personal Information remains protected to the standards described in this Privacy Policy. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.

If you are located in the European Economic Area (“EEA”) or Switzerland, we comply with applicable laws to provide an adequate level of data protection for the transfer of your Personal Information outside of the EEA. Where applicable law requires us to ensure that an international data transfer is governed by a data transfer mechanism, we use one or more of the following mechanisms: verification that the recipient is located in country with an adequate level of data protection, EU Standard Contractual Clauses with a data recipient outside the EEA, verification that the recipient has implemented Binding Corporate Rules, or verification that the recipient adheres to the EU-US and Swiss-US Privacy Shield Framework.

For Australian users, Permission Click uses the Microsoft Azure cloud computing service which is supported by a server housed in Sydney, Australia. This data system is not linked to or shared with any other data system and there is no transfer of data on that system, including your Personal Information, to other data systems or countries.

Retention

We will keep your Personal Information for as long as it remains necessary for the identified purpose or as required by law, which may extend beyond the termination of our relationship with you. Generally, we will not retain any student Personal Information beyond the time period required to provide the Services. We may retain certain data as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personally-identifiable data, account recovery, or if required by law. All retained Personal Information will remain subject to the terms of this Privacy Policy.

Upon termination of our relationship with a customer, or otherwise upon the instruction of our customer, we will delete all accounts and other Personal Information related to that customer’s end users.

Security

The security of your information is important to us. Permission Click operates secure data networks that are designed to protect your privacy and security. When we have collected information about you it cannot be seen or modified by anyone else. Permission Click has implemented acceptable standards of technology and operational security to ensure Personal Information (in both physical and electronic form) is protected against loss, misuse, interference and unauthorized access.

Only authorized Permission Click personnel and contractors are provided access to Personal Information and have agreed to ensure the confidentiality of this information. Reasonable steps are taken to destroy or permanently de-identify any Personal Information that is no longer required.

We review and update our security measures in light of current technologies. You should however be aware that the internet is not a secure environment and information sent via the internet (including email) cannot be guaranteed to be totally secure.

Children’s privacy

We are mindful and respectful of the privacy of children. As a risk management practice we will seek to engage with children under the age of 16 only via their parents, families, guardians or carers and obtain express parental consent for any collection of Personal Information about children. Permission Click does not knowingly collect Personal Information from children under the age of 16 without express parental consent.

Data quality, access and correction

Access

If you have an account with Permission Click then you may access your Personal Information at any time by logging into your account on our Website(s).

You may also at any time, request access to Personal Information that Permission Click holds about you by making a request to our Privacy Officer at the address or email address below.

We will endeavour to process any requests for access to Personal Information within a reasonable period of time. Where possible, we will provide you with access to that information either by providing you with copies of the information requested, allowing you to inspect the information requested, or providing you with a summary of the information held. If we need to deny your request for access we will let you know why and inform you how you may lodge a complaint regarding this decision. Generally, this will only be in cases where providing access would be unlawful or is subject to a potential legal claim or proceeding.

Permission Click may charge a nominal fee for supplying Personal Information where permitted under applicable laws.

Correction

If you have an account with Permission Click then you may change or correct your Personal Information at any time by logging into your account on our Website or by phoning us on the number below.

We will otherwise try to ensure that all information we collect, use or disclose about you is accurate, complete, up-to-date and relevant to the service being provided.

If you discover or suspect that there is an error or information is missing, please forward your request for correction to our Privacy Officer or other representative in your jurisdiction in writing at the relevant address or email address below. Our Privacy Officer will consider your request and as soon as practicable manage the correction of your Personal Information and will update you in writing. If your correction request is refused, our Privacy Officer will provide you within a reasonable period of time the reasons for such refusal and inform you of the complaint process (see below).

Complaints about privacy and our complaint handling procedure

If you have any complaints relating to the management of your Personal Information or if you believe there has been a breach of the applicable privacy laws by Permission Click, please forward your complaint in writing to our Privacy Officer at the address or email address below.

Our Privacy Officer will consider the complaint and advise you of their decision in writing within a reasonable time from receipt of the complaint. If our Privacy Officer decides that there has been a breach of the applicable privacy laws, s/he will endeavour to ensure that the breach is rectified within 30 days from the date of the decision and will update you in writing.

Contact Privacy Officer

You can contact our Privacy Officer using the following contact information or the contact information listed under the jurisdiction-specific contact information listed under Section 14:

Call Toll Free: 1-844-PERMISSION (737-6477)
Email: privacy@permissionclick.com

Updates to this Privacy Policy

Permission Click reserves the right to modify or amend this Privacy Policy at any time. We will provide notice of all material changes to the Privacy Policy and we will request consent for any new uses of Personal Information or other material changes to the Privacy Policy. The effective date of the current version of the Privacy Policy will be displayed at the beginning of the policy. Any changes are effective when we post the revised Privacy Policy on the Websites or Services.

We may provide you with disclosures and alerts regarding the Privacy Policy or Personal Information collected by posting them on our Websites and, if you are a User, by contacting you through your Permission Click dashboard, email address and/or the physical address listed in your Permission Click account.

Jurisdiction-Specific Provisions

Australia

We have policies and procedures to ensure that all Personal Information is handled carefully and securely in accordance with the Australian Privacy Principles contained in the Privacy Act 1988 (Cth). The term Personal information used in this Privacy Policy includes any “personal information” as that term is defined in the Privacy Act.

Please contact our Privacy Officer on the contact details below if you would like to:

  • enquire about or request access and/or update your Personal Information; or
  • report an alleged breach of your privacy rights or make a complaint:
  • talk to our Privacy Officer about our Privacy Policy

Post: Privacy Officer, Permission Click, 88 Adelaide Street, Winnipeg, MB, Canada, R3A 0W2.
Telephone: +61 03 9276 7788
E-mail: hello@permissionclick.com.au

If you are still not satisfied after lodging a complaint with us and have given us reasonable time to respond, then we suggest that you contact the Office of the Australian Information Commissioner by:

Phone: 1300 363 992 (local call cost, but calls from mobile and pay phones may incur higher charges). If calling from overseas (including Norfolk Island): +61 2 9284 9749

TTY: 1800 620 241 (this number is dedicated to the hearing impaired only, no voice calls.)

TIS: Translating and Interpreting Service: 131 450 (If you don’t speak English or English is your second language and you need assistance and ask for the Office of the Australian Information Commissioner)

Post: GPO Box 2999 Canberra ACT 2601
Fax: +61 2 9284 9666
Email: enquiries@oaic.gov.au

For more information about your privacy rights in Australia, visit the Office of the Australian Commissioner’s website, www.oaic.gov.au.

European Economic Area

Permission Click generally processes Personal Information in order to fulfill contracts we have with our customers and to pursue our legitimate business interests listed above. Otherwise, we will obtain consent from an individual in respect of processing of Personal Information.

With respect to personal data that Permission Click processes on behalf of our customers, such as a school board or other similar organization, Permission Click is a “data processor” and the customer is the “data controller” as those terms are defined under the General Data Protection Regulation (GDPR).

Individuals located in the EEA have certain rights under European law (including under the GDPR) with respect to Personal Information, including the right to request access to, obtain, correct, amend, delete, or limit the use of your personal data. Individuals who are located in to the EEA and who wish to exercise these rights, should contact Permission Click using the contact information above. If the inquiry relates to Personal Information collected by one of our customers or other third parties as a data controller, you should contact such third party. Individuals also have the right to make complaints to regulatory authorities in respect of our privacy practices.

United States (California)

California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their Personal Information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Information disclosed to those parties. As discussed above, we do not currently share Personal Information with third parties for their own marketing purposes. For more information, please contact our Privacy Officer.