Privacy Policy

Last updated: December 12, 2023

CentML Inc. (“CentML”, “we”, or “us”) values and respects your privacy. We have prepared this privacy policy (“Policy”) to explain the manner in which we collect, use, and disclose Personal Information (as defined below) when you visit our website located at https://centml.ai/ (the “Website”), use our services, or otherwise interact with us.

TABLE OF CONTENTS 

  1. COLLECTION AND USE OF PERSONAL INFORMATION
  2. SHARING OF PERSONAL INFORMATION
  3. INFORMATION ABOUT OUR WEBSITE
  4. INTEREST-BASED ADVERTISING
  5. SPECIFIC PROVISION FOR EU-RESIDENTS
  6. SPECIFIC PROVISION FOR CALIFORNIA RESIDENTS
  7. CHILDREN; CHILDREN’S PRIVACY
  8. SAFEGUARDS AND RETENTION
  9. YOUR CHOICES
  10. UPDATES TO THE PRIVACY POLICY
  11. CONTACT US
  12. OUR PRIVACY POLICIES AND PRACTICES

 

I.       COLLECTION AND USE OF PERSONAL INFORMATION 

We may collect personal information that identifies individuals or that may, with reasonable effort, identify individuals (the “Personal Information”) when you:

  • Register for and use our services
  • Sign up to receive marketing emails such as newsletters, offers, and updates
  • Participate in a CentML survey
  • Attend one of our events
  • Participate in any interactive features on our Sites including webinars, etc.
  • Apply for a job or consulting opportunity at CentML
  • Contact us

Registration and Use of the Services: When you sign up to receive our services, we will collect your name, company name, company address, email address (i.e., your username) and a password that you create. You will also have the option to add information to your account profile, such as payment information. You are required to keep your username and password secure and not share it with anyone else. We will never ask you for your password in any unsolicited communication (such as letters, phone calls or email messages).

We may monitor use of our services by our customers or other authorized users in order to detect, investigate, or prevent any actual or potential violation of our terms and conditions. We may also generate aggregated, non-identifiable data and use such information to monitor the performance, use and stability of the services and to improve the services.

Payment: If you purchase our services, we (or our authorized third-party payment processor) will collect your full name and payment information (including billing address, credit card number, expiry date and CVV code) in order to process the transaction and enable us to provide you with the services you have purchased.

  • Please note that at this time, we are using Stripe, a third-party payment processor. This can be updated by CentML at any time for any reason. If you decide to access or use a third-party service (including, but not limited to, Stripe), your activity and use is governed by the third-party Service’s terms and conditions (below), not by those of CentML

Marketing Communications: If you sign up to receive email marketing communications, we will collect your email address in order to send you newsletters, offers, and updates that may be tailored to your interests and preferences.  You can unsubscribe at any time by clicking the “unsubscribe” link included at the bottom of each email. Alternatively, you can opt-out of receiving email marketing communications by contacting us at the contact information provided in the “Contact Us” section below.  Please note that you may continue to receive transactional or account-related communications from us.

Surveys: From time to time, we may offer you the opportunity to participate in one of our surveys on an optional basis. We use the information collected through our surveys to help us understand our customers’ needs and interests and to develop and improve our services and the Website.

Events: If you attend one of our events or webinars, we may collect your full name, email address, city, province, postal code, country, phone number, and any other information you may provide us in connection with the event or webinar. We collect this information so that we can communicate with you about the event and contact you about future events.

Employment: In connection with a job application or related inquiry, you may provide us with certain Personal Information about yourself (such as that contained in a resume, cover letter, or similar employment-related materials). We use this information for the purpose of processing and responding to your application for current and future career opportunities.

Contact Us: When you contact us with a comment, question or complaint through email or telephone, you may be asked for information that identifies you, such as your name, email address, address and a telephone number, along with additional information we need to help us promptly answer your question or respond to your comment or complaint.  We may retain this information to assist you in the future and to improve our services. In addition, we may monitor and record our telephone conversations with you for documentation, training, and quality assurance purposes.

Non-Identifiable Information: We may also collect certain unidentifiable, non-personal information through the use of the services (the “Non-Personal Information”). Non-Personal Information is information that cannot be used to identify a specific individual.  As such, we are not aware of the identity of the user from which the Non-Personal Information was collected.  We also collect aggregate user data regarding the use of our services. We may modify the information collected through the service or via other means so that the information cannot personally identify a specific individual. Our use and disclosure of such aggregated or anonymous  information is not subject to any restrictions under this Policy, and we may disclose it to others without limitation and for any purpose. For the avoidance of doubt, if we combine Personal Information with Non-Personal Information (e.g., analytical data), the combined information will be treated as Personal Information so long as it remains combined.

II.      SHARING OF PERSONAL INFORMATION

We do not sell or disclose your Personal Information to third parties without your consent, except as set forth below or as required or permitted by law.

Service Providers: Your Personal Information will be transferred (or otherwise made available) to certain third parties that provide services on our behalf. We use service providers to provide services such as hosting the Website, processing payments, and providing analytics, advertising and marketing services. Our service providers are only provided with the information they need to perform their designated functions and are not authorized to use or disclose Personal Information for their own marketing or other purposes. We and our service providers may access, store and otherwise process Personal Information outside of Canada (and, for residents of Quebec, outside of Quebec), including in the United States or other foreign jurisdictions, as may be appropriate, where we or our service providers are located.

Legal and Compliance: We and our Canadian, U.S. and other foreign service providers may disclose your Personal Information in response to a search warrant or other legally valid inquiry or order, or to another organization for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise may be required or permitted by applicable Canadian, U.S. or other law or legal process, which may include lawful access by U.S. or foreign courts, law enforcement or other government authorities. Your Personal Information may also be disclosed where necessary for the establishment, exercise or defence of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.

Sale of Business: We may transfer any information we have about you as an asset in connection with a proposed or completed merger, acquisition, financing, or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of CentML or as part of a corporate reorganization or other change in corporate control.

III.    INFORMATION ABOUT OUR WEBSITE

Visiting our Website:  In general, you can visit our Website without telling us who you are or submitting any Personal Information. However, we collect the IP (Internet protocol) addresses of all visitors to our Website and other related information, such as page requests, browser type, operating system and average time spent on our Website. We use this information to help us understand website activity and to monitor and improve our Website.

Cookies:  Our Website uses a technology called “cookies”. A cookie is a tiny element of data that our Website sends to a user’s browser, which may then be stored on the user’s hard drive so that we can recognize the user’s computer or device when they return. You may set your browser to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from our Website, you may not be able to take advantage of all of the Website’s features.

Analytics: We may use a third party such as Google Analytics to help us gather and analyze information about the areas visited on the Website (such as the pages most read, time spent, search terms and other engagement data) in order to evaluate and improve the user experience and the Website. These third parties may use cookies and other tracking technologies. For more information about Google Analytics or to prevent the storage and processing of this data (including your IP address) by Google, you can download and install the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en. You can also obtain additional information on Google Analytics’ data privacy and security at the following links:

Third-Party Links: Our Website may contain links to other websites that CentML does not own or operate. We provide links to third-party websites as a convenience to the user. These links are not intended as an endorsement of or referral to the linked website. The linked websites have separate and independent privacy policies, notices and terms of use. We do not have any control over such websites, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose, secure and otherwise treat Personal Information. We encourage you to read the privacy policy of every website you visit.

IV.    INTEREST-BASED ADVERTISING

We work with third parties such as ad networks and other advertising companies that use their own tracking technologies (including cookies and pixel tags) on our Website in order to provide you with tailored advertisements across the Internet. These companies may collect information about your activity on our Website and third-party websites (such as web pages you visit and your interaction with our advertising and other communications) and use this information to make predictions about your preferences, develop personalized content and deliver ads that are more relevant to you on third-party websites. This information may also be used to evaluate the effectiveness of our online advertising campaigns.

Opting Out of Interest-Based Advertising: For more information about  interest-based advertising and to understand your options, including how you can opt out of receiving behavioural ads from third-party advertising companies participating in the Digital Advertising Alliance of Canada, please visit the Digital Advertising Alliance of Canada website at http://youradchoices.ca/choices.

Please note that even if you opt out of interest-based advertising by a third party, these tracking technologies may still collect data for other purposes, including analytics, and you will still see ads from us, but the ads will not be targeted based on behavioural information about you and may therefore be less relevant to you and your interests.

To successfully opt out, you must have cookies enabled in your web browser (see your browser’s instructions for information on cookies and how to enable them). Your opt-out only applies to the web browser you use so you must opt out of each web browser on each device you use. Once you opt out, if you delete your browser’s saved cookies, you will need to opt out again.

V.      SPECIFIC PROVISION FOR EU-RESIDENTS 

This Section applies to you, if you are from the European Union. CentML adopted the following provisions, to comply with the EU 2016/679 Directive General Data Protection Regulation (“GDPR”), pursuant to which CentML will be considered as a “Data Controller” with respect to our use of Personal Information of resident of the European Union.

  • Legal Basis. We base our processing of any personal data as “Data Controllers” based on the following lawful grounds: CentML relies, primarily, on your consent to the terms of this Policy and the terms set forth under our Terms of Service, as a legal basis for processing:
    • any Personal Information related to you or communicating any other promotional material
    • may collect and use your Personal Information when it is necessary for one of the legitimate uses set out in Section ‎I above, which we believe are not overridden by your fundamental rights.
    • may process your Personal Information to comply with a legal obligation and to protect our users’ vital interests. If, at any time, you wish to exercise your rights in accordance with the provisions provided by law you may send us an email to privacy@centml.ai and request to access your Personal Information together with information about how, and on what basis, such information is being processed. Should you desire to receive such information in a different format than the one that was provided to you, you can contact us via privacy@centml.ai and we shall use commercially reasonable efforts to accommodate your request, if applicable; rectify any of the Personal Information being held when such information is inaccurate; to delete or restrict access to your Personal Information in limited circumstances as described under the GDPR. Please note that if we need to delete any Personal Information related to you, as per your request, it can take time until we completely delete residual copies of such data from our servers and backup systems.
    • to withdraw your consent to the processing of your Personal Information. However, please note that exercising this right will not affect the lawfulness of any previous processing activities based on consent that was lawfully obtained before its withdrawal.
    • to obtain and reuse your Personal Information for your own purposes across different services, as part of your right to data portability.
  • ‍Please note that you have the right to complain to a Data Protection Authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority in the European Economic Area (EEA).
  • If you have any concerns with respect to our methods of processing any Personal Information related to you, or if you wish to withdraw your consent, for any reason, kindly let us know by sending an email to privacy@centml.ai.
  • If you reside in a country from the European Economic Area, then, by agreeing to the terms of this Policy, you agree to CentML sharing your Information outside of the European Economic Area. These transfers are subject to special rules under data protection laws. If this happens, we will ensure that the transfer will be compliant with data protection law and all personal data will be secure. Our standard practice is to use ‘standard data protection clauses’ which have been approved by the European Commission for such transfers.
  • CentML shall not charge you for requesting to exercise any of the aforementioned rights.

VI.    SPECIFIC PROVISION FOR CALIFORNIA RESIDENTS

This Section applies to you only if you reside in the State of California, United States. CentML adopted the following provisions to comply with the California Consumer Privacy Act (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this Section ‎‎VI.

  • The following categories reflect the type of Personal Information which CentML has collected within the last twelve (12) months:
    • Identifiers and Personal Information as listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), for example, first names, surnames, telephone numbers, address, online Identifier, Internet Protocol address, business or private email addresses, account usernames, as well as Personal Information as such term is defined in this Policy.
    • Electronic network activity information, including, but not limited to, browsing history and any additional information related to your interaction with our Service.
    • CentML has obtained such information as set forth in this Section and Personal Information as provided under Section ‎I above (for the purpose of this Section , the “Personal Data”).
    • CentML may use the Personal Data it collects or receives for its legitimate interests (as set out in Section I above), which CentML believes are not overridden by your fundamental rights. CentML may also disclose such Personal Data to third parties for its legitimate purposes as described in Section II above.
  • In the preceding twelve (12) months, CentML has disclosed the following Personal Data for our business purposes:
    • Identifiers (including your name, email address, profession).
    • Personal Data’s categories as listed in the California Customer Records statute).
    • Inferences.
  • Identifiers and Personal Information as listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), for example, first names, surnames, telephone numbers, address, online Identifier, Internet Protocol address, business or private email addresses, account usernames, as well as Personal Information as such term is defined in this Policy.
  • Electronic network activity information, including, but not limited to, browsing history and any additional information related to your interaction with our Service.
  • CentML has obtained such information as set forth in this Section VI above and Personal Information as provided under Section I above (for the purpose of this Section ‎VI, the “Personal Data”).
  • CentML may use the Personal Data it collects or receives for its legitimate interests (as set out in Section I above), which CentML believes are not overridden by your fundamental rights. CentML may also disclose such Personal Data to third parties for its legitimate purposes as described in Section ‎II above.
  • In the preceding twelve (12) months, CentML has not sold any of your Personal Data.
  • Your rights as a California Resident. You are entitled to request the following specific rights under the CCPA, solely with respect to Personal Data related to you:
    • Request to know (a) what categories and specific components of Personal Data we collect about you and from which sources; (b) categories of Personal Data that we disclosed for the purpose described in Section I above, and the categories of third parties with whom we have shared any particular category of your Personal Data. If we disclose any of your Personal Data to a third-party, we will provide you, after authenticating your identity, with a list that will identify the specific category of your Personal Data which was disclosed.
    • Request that we delete any Personal Data we collect about you. After authenticating your identity, we will delete (and direct our service providers to delete) any Personal Data related to you from our records, unless an exception applies. Please note that if we need to delete any Personal Data related to you following your request, it can take time until we completely delete residual copies of Personal Data from our servers and backup systems.
    • Instruct us not to sell any Personal Data related to you that was collected by us.
    • You have the right not to be discriminated against by CentML, for exercising your rights under the CCPA.
    • If you have any concerns about how we process Personal Data related to you, or if you wish to withdraw your consent, for any reason, kindly let us know by sending an email to privacy@centml.ai. Please note that exercising this right will not affect the lawfulness of any previous processing activities based on consent that was lawfully obtained before its withdrawal. Also, please note that CentML shall not charge you for requesting to exercise any of the rights set forth in this Section.

    VII.   CHILDREN; CHILDREN’S PRIVACY

    CentML’s services are intended for the general public but are generally not directed at children . We do not knowingly collect or solicit Personal Information (as defined by the U.S. Children’s Privacy Protection Act, or “COPPA”) from anyone under the age of 18 in a manner prohibited by the COPPA. If you are a parent or guardian and you have reasons to believe that we have collected Personal Information from your underaged child in a manner not permitted by law, please contact us by sending an email to privacy@centml.ai, stating “Minors Content Removal Request” in the subject line, and tell us what information you want us to remove. We will remove any such data to the extent required by applicable law.  If you are a California resident under 18 years old and registered to use the Service, you can ask us to remove any content or information you have posted on the Service. To make such a request, email us to privacy@centml.ai stating “California Under 18 Content Removal Request” in the subject line, and tell us what information you want us to remove. We will make reasonable good faith efforts to remove the post from prospective public view, although we cannot ensure the complete or comprehensive removal of the content and may retain the content as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

    VIII.  SAFEGUARDS AND RETENTION

    We have implemented reasonable administrative, technical and physical measures in an effort to safeguard the Personal Information in our custody and control against theft, loss and unauthorized access, use, modification and disclosure. We restrict access to Personal Information on a need-to-know basis to employees and authorized service providers who require access to fulfil their job requirements.

    We have record retention processes designed to retain Personal Information for no longer than necessary for the purposes set out in this Policy or as otherwise required to meet legal or business requirements.

    We may also retain aggregate information beyond this time for research purposes and to help us develop and improve our services. You cannot be identified from aggregate information retained or used for these purposes.

    Please DO NOT send us any communication which contains confidential or sensitive information, since we are unable to evaluate whether your content constitutes as confidential or sensitive information, or not, and we may retain or use such communication as described hereinabove, and such retention or use shall not be deemed as a breach of any of our obligations pursuant to this Policy.

    IX.    YOUR CHOICES

    Marketing Communications As indicated above, if you have signed up to receive our email communications, you can unsubscribe any time by clicking the “unsubscribe” link included at the bottom of the email. Alternatively, you can opt out of receiving our email communications by contacting us using the contact information under “Contact Us” below.

    Exercising Your Privacy Rights

    Subject to applicable law, you have the right to access, update and correct inaccuracies in, and withdraw consent to our collection, use and disclosure of your Personal Information in our custody or control. You may make such a request or withdraw your consent by emailing or writing to us using the contact information set out below. We may request certain Personal Information for the purpose of verifying your identity.

    To opt out of interest-based advertising, see the “Interest-Based Advertising” section above.

    X.      UPDATES TO THE PRIVACY POLICY

    We may update this Policy periodically to reflect changes to our privacy practices. We encourage you to periodically review this page to ensure you are familiar with those changes. We will indicate at the top of this Policy when it was most recently updated.

    XI.    CONTACT US

    If you have any questions or comments about this Policy or the manner in which we or our service providers (including our service providers outside Canada) treat your Personal Information, or to exercise any rights in respect of your Personal Information, please contact us at:

    Chief Privacy Officer

    privacy@centml.ai

    XII.   OUR PRIVACY POLICIES AND PRACTICES

    We are committed to protecting Personal Information and have implemented policies, procedures, and practices that govern our treatment of Personal Information. These policies and procedures include, among other things, the following:

    • We have implemented policies and procedures to protect Personal Information in our custody and control from unauthorized access, use or disclosure.
    • We have implemented processes to respond to data subject requests and complaints in a timely and effective manner.
    • We have implemented a framework for the retention and destruction of Personal Information to ensure compliance with legal obligations, and to securely destroy Personal Information once no longer required based on legal and business needs.
    • We have designated a Privacy Officer, who is responsible for overseeing the organization’s compliance with applicable privacy legislation.
    • We have implemented a privacy framework that defines the roles and responsibilities for our employees with respect to the treatment of Personal Information.