October 5, 2015

Privacy Policy

RefinePro Inc. (“RefinePro”/“we”/“us”/“our”) is committed to protecting your privacy. This Privacy Policy applies to http://refinepro.com/ (the “Website”) and to our web-based data transformation and analytic utility (the “Service”) which is accessible at http://app.refinepro.com/ and as further described in our Terms of Use. This Privacy Policy describes how we collect, store, use and distribute certain Personal Information (as defined below) of yours that we may collect through the Website and the Service. Note that RefinePro does not access, use, view or share any data that you upload to our Website unless required to by law. Any capitalized terms not defined in this Privacy Policy shall have the meaning given to such terms in our Terms of Use. This Privacy Policy is to be read together with and form part of our Terms of Use.

Consent

By using the Website or the Service you consent to the use of your Personal Information as outlined in this Privacy Policy. Your Personal Information will not be used for any purposes other than those described in this Privacy Policy. You may withdraw your consent to our use of your Personal Information at any time by ceasing to use the Website and the Service. Except as otherwise stated herein, this Privacy Policy applies to all of the Personal Information of yours that RefinePro has on record.

Collection of Information

RefinePro collects, uses and discloses only such Personal Information as is required to manage User accounts, to provide the Service, to maintain our customer lists, to respond to User inquiries, for the identification and authentication of Users, for the improvement of the Service, as required to comply with applicable laws and where compelled to by law enforcement. Unless otherwise agreed (and subject to any exclusions and disclosures described herein) we will not disclose your Personal Information to any third parties.

 

“Personal Information”: In this Privacy Policy Personal Information means personally identifiable information, such as your name, address, location, e-mail address, credit card information, birth date and gender. RefinePro collects and stores some Personal Information relating to your account registration, communications between you and RefinePro, your use of the Service and customer support. Personal Information does not include data that you upload to the Website.

Collection and Use of Personal Information:

RefinePro collects Personal Information for the following purposes:

Registration Information: We collect some Personal Information when you create an account with the Service, including your name, username, password, and email address.

Transactional Notifications: We provide notice to Users of certain occurrences relating to the Service, for example, we may send you a notification of an update to our Terms of Use or Privacy Policy, for example.

Marketing Communications: You may choose to receive emails from us regarding new features and updates to the Service. You may withdraw your consent to receiving such emails from us at any time by following the opt-out instructions in any such email, or by contacting RefinePro with your request at support@refinepro.com.

Hardware & Software Information: RefinePro collects some information on the hardware and software of the device through which you access the Service, such as device model, screen size, operating system version, etc..

If we plan to use your Personal Information in the future for any purposes not identified above, we will only do so after informing you by updating this Privacy Policy (see further Amendments to this Policy below).

Disclosures & Transfers

We have put in place contractual and other organizational safeguards to help ensure the protection of your Personal Information (see further Security below). In addition to these measures, we will not disclose or transfer your Personal Information to third parties without your permission, except as otherwise specified in this Privacy Policy (see further Important Exceptions below).

Some or all of the Personal Information that we collect may be stored on servers that are situated in Canada and/or the United States and thus, irrespective of the safeguards we have put in place for the protection of your Personal Information, such Personal Information will, under a lawful order, be accessible to the Canadian and/or United States governments or their respective agencies.

Important Exceptions

We may disclose your Personal Information without your consent and without notifying you if required to do so by law or in the good-faith belief that doing so is necessary to: (i) conform to the law or to comply with legal process served on RefinePro; (ii) protect and defend the rights or property of RefinePro; (iii) to identify, contact or bring legal action against someone who may be (either intentionally or unintentionally) causing injury to or interfering with our rights or property or the rights or property of Users of the Service; and (iv) act under exigent circumstances to protect the personal safety of our Users or the general public.

We may also disclose your Personal Information in connection with a corporate re-organization, a merger or amalgamation with another entity, a sale of all or a substantial portion of our assets or stock, including any due diligence exercise carried out in relation to the same, provided that the information disclosed continues to be used for the purposes permitted by this Privacy Policy by the entity acquiring such information.

Security

The security of your Personal Information is important to us, and we use commercially reasonable efforts to store and maintain your Personal Information in a secure environment. We take technical, contractual, and administrative security measures in order to protect the Personal Information that we collect. We have implemented procedures designed to limit the dissemination of your Personal Information to only such parties as are reasonably necessary to carry out the stated purposes we have communicated to you. You are also responsible for helping to protect the security of your Personal Information, for example, by never sharing your username and password for the Service with anyone else.

Children’s Privacy

Persons under the age of 13 are not permitted to use the Service, and we do not knowingly collect information about such persons. If you think we have collected any such information, please contact us and we will endeavour to remove such information from our systems.

Retention

We will keep your Personal Information for as long as necessary for the identified purpose or as required by law, which may extend beyond the termination of our relationship with you. We may retain certain information 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. Even if you request that we do so, it may not be possible for us to completely delete all of your Personal Information due to technological and/or legal constraints.

Amendments to this Policy

We reserve the right to change this Privacy Policy at any time without notice to you. However, if we decide to change this Privacy Policy in the future we will endeavour to notify you via a posting on the Website or by e-mail sent to the email address associated with your account. The latest version of this Privacy Policy will always be available here www.RefinePro.com/privacy. Any non-material changes (such as clarifications) to this Privacy Policy will become effective on the date that the revised policy is posted and made accessible to Users. Any material changes will become effective on the earlier of: (i) thirty (30) days from the date that the revised policy is posted and made accessible to Users, or (ii) when the User’s express consent to the revised policy is given to RefinePro. The materiality of changes to this Policy is the exclusive determination of RefinePro.

The date on which the latest revision was made to this Privacy Policy is indicated at the bottom of this page. We recommend that you print a copy of this Privacy Policy for your reference and revisit this Privacy Policy from time to time to ensure you are aware of any changes. Your continued use of the Service signifies your acceptance of any changes to this Privacy Policy.

Access and Accuracy

You have the right to access the Personal Information we hold about you in order to verify its accuracy and to a general accounting of how we use that information. Upon receipt of a written request from you, we will provide you with a copy of your Personal Information. We will endeavor to deal with all requests for access and modifications in a timely manner. To avoid delays in obtaining a record of your Personal Information, please provide sufficient detail to permit us to identify you and the specific information that you are requesting. Please note that in certain limited circumstances we may not be able to make all relevant information available to you, such as where the requested information also pertains to another User or other third party or where it contains confidential commercial information. In such circumstances we will provide the reasons for the denial of your request.

We will make every reasonable effort to keep your Personal Information accurate and up-to-date, and we will provide you with mechanisms to update, correct, delete or add to your Personal Information as appropriate. As appropriate, such amended Personal Information will be transmitted to those parties to which we are permitted to disclose your Personal Information in accordance with this Privacy Policy. Having accurate Personal Information about you enables us to give you the best possible service.

Contact Us

If you have any question regarding this Privacy Policy, or if you would like to make a request to access your Personal Information please contact us at support@refinepro.com.

Last Updated: October 19, 2014