- the types of personal information we collect about you;
- the purposes for which we collect that information;
- how we use that information;
- with whom we share that information;
- how we safeguard that information;
- the choices available to you regarding how we use your personal information; and
- how you can contact us about our privacy practices.
2. What personal information do we collect?
3. What is the purpose of the collection and use of your personal information?
4. To whom do we disclose your personal information?
5. What if there is a change in the initial purpose of collection of your personal information?
6. Do we knowingly collect personal information about children?
7. How do we safeguard your personal information?
8. Do we transfer your personal information to third parties located in Canada or other jurisdictions for storage or processing?
9. How long do we retain your personal information?
10. Do we collect, use, and disclose non-personal information about you?
11. How do we ensure the accuracy of your personal information?
12. How can you access your personal information?
13. What types of “cookies” and/or other technologies do we use and how can you change your “cookie” settings?
15. Do we use third party advertising partners? If so, how can I opt out of targeted advertising?
16. What type of analytics services do we use and for what purpose? How can you disable analytics?
17. Who do you contact if you have an inquiry, complaint, or want to request a review of your personal information?
18. How do we handle complaints?
19. How do you withdraw your consent to the collection, use or disclosure of your personal information?
20. How can you unsubscribe from our commercial electronic messages such as messages regarding new products or services?
“collection” means the act of gathering, acquiring, recording or obtaining personal information from any source, including third parties, by any means.
“consent” means voluntary agreement with the collection, use and disclosure of personal information for defined purposes. Consent can be either express or implied and can be provided directly by the individual or by an authorized representative, such as a parent or guardian. Express consent is permission that is granted by an individual taking a positive step to signify consent and may be given orally, electronically or in writing. Implied consent is the assumption of consent that can reasonably be inferred from a user’s action or inaction.
“user” means an individual who uses the Service provided by Delphi, including anyone else who accesses or visits the Sites and the Service.
“disclosure” means making personal information available to a third party.
“personal information” means information about an identifiable individual, but not aggregated information that cannot be associated with a specific individual.
“registered user” means a user who has created and registered an account with Delphi, as well as a Subscribing Organization that has created and registered an account or accounts with Delphi.
“Subscribing Organization” means a company, entity or organization, including any business that has subscribed to the Service on behalf of its clients or users.
“third party” means an individual other than the user, or the user’s agent, or an organization other than Delphi or a Subscribing Organization.
“use” means the treatment, handling and management of personal information by and within Delphi.
“user ID number” means the unique number assigned to each registered account once created.
2. Personal Information We Collect
When you interact with us through the Service, we may collect or receive the following types of information.
Personal Information You Provide To Us
You may provide us with your personal information in different ways. For example, we may collect any or all of the following personal information if the information is reasonably required to provide the Service to you:
(a) information that you provide when you become a registered user or otherwise complete forms on the Service, such as your name, company name, birth date, email address, social media user ID, postal address, telephone number, and country of residence;
(b) your log-in and password details in connection with your Delphi account(s), including your username;
(c) information that you provide to Delphi when you subscribe to the Service, such as your billing address, payment method and credit card information;
(d) your correspondence with Delphi employees and independent contractors, including any questions, concerns or comments you may have about the Service or problems that you report;
(e) comments, videos, photographs, and any other content or information that you may submit to the Service;
(f) details of your requests made through the Service.
Usage Information We Collect Automatically
When you visit the Sites, we may collect, using electronic means, usage information. This information may include:
(a) the Internet Protocol (or IP) address of your computer;
(b) browser type and language;
(c) operating system;
(d) resolution of screen;
(e) device type and device identifiers;
(g) material and pages viewed;
(h) time and date of access to the Service;
(i) number of bytes transferred;
(j) number of clicks per visit; and/or
(k) the site you came from and searched for keywords if arriving from a search engine.
Delphi may use or disclose aggregated usage information to third parties such as Universities for research purposes. These third parties will not have access to user ID numbers and therefore will not be able to use same to identify the individual to whom the usage information relates.
Personal Information Posted by You or Others to the Service
If you voluntarily submit or post any information, videos, photographs or other content (“User Content”) to the Service, certain of your personal information may be included in the posting, such as your user name and email address, and this information may be collected and used by others. Delphi has no control over and is not liable for the collection, use or disclosure of any posted User Content or your included personal information by users of the Service. You are responsible for ensuring the protection of any of your personal information that you post to any other user’s account, Delphi messaging account or to the Sites or Service.
3. Purpose of Collection and Use of Personal Information
Delphi collects your personal information and will use your personal information as is reasonably required for the following purposes:
(a) if you are a registered user, to establish and maintain your Delphi account;
(b) to provide web applications, the Service, and/or the other services or information that you request;
(c) to verify your identity if you submit comments, videos, photographs, opinions, or any other content or information to the Service;
(d) to respond to questions, comments, requests, job applications, or complaints that you submit to Delphi;
(e) to collect amounts owing from you to Delphi, if applicable;
(f) to track communications with you;
(g) to analyze use of the Service and to improve the Service;
(h) to send emails, newsletters, regular mail or other communications you have consented to receive from Delphi;
(i) to provide Service-related announcements or notifications to you;
(j) to aggregate your personal information resulting from the combination and/or aggregation of certain raw personal information collected from you with other data in a way that no longer personally identifies you;
(k) to display advertising on the Service or to manage and serve our advertising on other sites. See Section 14 on targeted advertising and how you may opt out;
(l) to fulfill a purpose that we disclose to you when we request your personal information; and/or
(m) to meet legal and regulatory requirements.
You have given your consent for the collection and use of your personal information. If you are a Subscribing Organization, you acknowledge that you have obtained express consent from your clients or users for you to use the Service. Personal information will only be collected and used by Delphi and its employees, independent contractors, agents, partners and service providers in a manner consistent with the activities of Delphi. Access to your personal information by Delphi employees, independent contractors, agents, partners and service providers is limited only to those authorized, based on their need to deal with the personal information for the reason(s) for which it was obtained, including to enable them to perform a business, professional or technical support function for Delphi.
Delphi does not collect information related to method of payment such as a credit or debit card number. All purchases of Delphi products and services will be directed to and handled by third parties such as Stripe. You will be bound by the privacy policies of these third party sites.
4. Disclosure of Personal Information
Delphi may disclose your personal information to:
(a) its employees, agents, partners, distributors, retailers and service providers as is reasonably necessary to enable these parties to perform a business, professional or technical support function for Delphi;
(b) a person who, in the reasonable judgment of Delphi, is seeking the information as your agent; and
(c) a third party or parties, where you consent to such disclosure or the disclosure is permitted or required by law.
Corporate Reorganization and Business Transfers
5. Change of Purpose
Delphi will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and obtain your express consent to do so pursuant to Section 21.
Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law.
The Service is intended for general audiences and is not directed to children under the age of 16. We do not knowingly collect personal information from children under 16. In the event that we learn that we have collected personal information from a child under the age of 16, we will take appropriate steps to delete that personal information. If you become aware or believe that a child has provided us with personal information, please contact us as provided in Section 17.
7. Safeguarding Your Personal Information
Delphi is committed to safeguarding your personal information. Delphi uses appropriate security measures to protect personal information against risks such as loss or theft, unauthorized access, disclosure, copying, misuse, modification or destruction, and any other unlawful form of processing of the personal information in our possession regardless of the format in which it is held. The methods of protection and safeguards used by Delphi include, but are not limited to:
- Administrative safeguards such as privacy and security policies and procedures, privacy and data protection training for Delphi staff and agents;
- Technical safeguards such as security testing, vulnerability scans, and technological measures, including the use of passwords, encryption, firewalls, and secure coding frameworks;
- Physical safeguards such as locked filing cabinets, and need-to-know access for Delphi employees and independent contractors.
Delphi also ensures that its employees with access to personal information are made aware of the importance of maintaining the confidentiality of personal information.
Delphi takes care in disposing of or destroying personal information to prevent unauthorized parties from gaining access to the information.
While Delphi is committed to safeguarding your personal information, we cannot ensure or warrant the security of any personal information we collect either directly or automatically from you, and you do so at your own risk.
Delphi can not guarantee that such personal information may not be accessed, disclosed, altered, or destroyed by breach of any of our security safeguards. To the degree that personal information is of a sensitive nature, in the event of a breach, there may be a risk of significant harm to you which includes bodily harm, humiliation, damage to reputation or relationships, loss of employment, business or professional opportunities, financial loss, identity theft, negative effects on the credit record and damage to or loss of property.
Delphi also cannot guarantee that information sent or received over the Internet is secure and does not make any representation or warranty concerning the security of personal information communicated to or from Delphi via the Internet or regarding the interception by third parties.
8. Cross Border Transfer of Personal Information
Subject to any contractual restrictions as between Delphi and a Subscribing Organization, your personal information may be stored and processed in any country (e.g. Canada, United States) where we engage third party service providers.While such information is outside of your country of residence, it is subject to the law of the country in which it is held, and may be subject to disclosure to the governments, courts, or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country. For example, personal information stored in the United States is subject to the US PATRIOT ACT.
Where and when appropriate, we will transmit amended personal information to third parties having access to the personal information in question.
9. Retention of Personal Information
Delphi will only keep personal information for as long as reasonably necessary to fulfill the relevant purposes set out in the Policy Privacy and in order to comply with our legal and regulatory obligations. To determine the appropriate retention period for your information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of your information, the purposes for which we process your information and whether we can achieve those purposes through other means, and the applicable legal requirements.
10. Non-Personal Information
We may collect, use and disclose non-personal information, including aggregated data resulting from the combination and/or aggregation or certain raw data collected from you with other data in a way that no longer personally identifies you. We make no attempt to link this non-personal information with the identity of individuals. We may permanently archive non-personal information for future use in any manner whatsoever.
11. Accuracy of Personal Information
Delphi is committed to keeping your personal information as complete, up-to-date and accurate as is necessary for the purposes for which it is to be used. Delphi will promptly correct or complete any personal information found to be inaccurate or incomplete. Where appropriate, Delphi will transmit amended information to third parties having access to the personal information in question.
12. Access to Personal Information
Upon request, Delphi will provide you with a reasonable opportunity to review the accuracy of your personal information. Such personal information will be provided within a reasonable time of the request and at a minimal or no cost to you.
Also upon request, Delphi will provide an account of the use and disclosure of your personal information and, where reasonably possible, will state the source of the information. In providing an account of disclosure, Delphi will provide a list of organizations to which it may have disclosed personal information about you when it is not possible to provide an actual list.
In certain situations, Delphi may not be able to provide access to all of the personal information we hold about you. In such a case, we will provide the reasons for denying access upon request. Such reasons may include:
(a) if doing so would likely reveal personal information about another individual that cannot be severed or the information could reasonably be expected to threaten the life or security of another individual;
(b) if doing so would reveal any of our confidential information;
(c) if the information is protected by solicitor-client privilege;
(d) if the information was generated in the course of a formal dispute resolution process; or
(e) if the information was collected in relation to the investigation of a breach of an agreement or a contravention of a federal or provincial law, or that of a foreign jurisdiction.
13. Cookies and Similar Technologies
The Sites use “cookies”, which are small text files placed on your computer or other device when you visit a website. When you visit the site again, the cookie allows that site to recognize your browser. Cookies may store user preferences and other information.
There are three main types of cookies:
(a) Session Cookies are specific to a particular visit and limited to sending session identifiers (random numbers generated by the server) so you don’t have to re-enter information when you navigate to a new page or check out. Session cookies are not permanently stored on your device and are deleted when the browser closes;
(b) Persistent Cookies record information about your preferences and are stored in your browser cache or mobile device and remain on your device between browsing sessions. For example, a persistent cookie may be used on a website to remember your log-in details so you will not need to enter those details each time you visit that website; and
(c) Third Party Cookies placed by someone other than us which may gather data across multiple websites or sessions.
We use the below listed cookies to perform the following functions:
(a) Strictly Necessary / Technical Cookies that are essential to enable you to move around a website and use its features. You cannot withdraw your consent to the use of these types of cookies because without them, the Service cannot be provided.
(b) Analytical / Performance Cookies that collect information in aggregated form about how users interact with the Sites so that we may improve functionality. These cookies are sometimes placed by third party providers which enable features or functionality provided by third parties in connection with the Service. For example, advertising, interactive content, and analytics (see Section 16 below). The parties that set these third-party cookies can recognize your device both when it visits the website in question and also when it visits certain other websites.
(c) Functional Cookies that allow a website to remember choices you make, recognize you when you return and to personalize content.
(d) Targeting / Advertising Cookies that track browser habits and used to deliver targeted (interest-based) advertising based on your browsing activities and interests. See Section 15 on how you may opt out of targeting advertising.
We may use other technologies similar to cookies like web beacons, which are sometimes called “tracking pixels” or “clear gifs”. These are tiny graphics files that contain a unique identifier that enable us to recognize when someone has visited the Sites or opened an email that we have sent them. In many instances, these technologies are reliant on cookies to function properly, and so declining cookies will impair their functioning.
Right to Refuse the Use of Information Collection Technologies
We obtain your consent to our information collection technologies through our opt-in mechanism on our website. You have the right to object to the use of information collection technologies such as cookies. Regular cookies may generally be disabled or removed by tools that are available as part of most commercial browsers, and in some but not all instances can be blocked in the future by selecting certain settings. Each browser you use will need to be set separately and different browsers offer different functionality and options in this regard.
Please be aware that if you disable or remove these technologies you may find that certain functions and features will not work as intended on the Service and that when you revisit our website your ability to limit cookies is subject to your browser settings and limitations.
14. Links to Other Websites
15. Targeted Advertising and How You May Opt Out
We may use third party advertising partners such as advertising networks, exchanges, and social media platforms to display advertising on the Service or to manage and serve our advertising on other sites. You have a variety of options to opt out of interest based advertising ranging from browser controls, add on utilities such as ad blockers, and other opt out tools. Opt out tools may include organizations such as:
- Network Advertising Initiative: https://optout.networkadvertising.org/?c=1,;
- Digital Advertising Alliance (“DAA”) of Canada: https://youradchoices.ca/;
- DAA YourAdChoices: https://youradchoices.ca/en/tools.
The Service employs Google Analytics, a web analysis service from Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). Google Analytics uses “cookies,” which are text files placed on your computer, to help the website analyze how users use the Service, compiling reports on the activity of the Service for the Services’ operators and providing other services relating to website activity and Internet usage. The information generated by the cookie (including the IP address) is transferred and stored on a Google server located in the United States.
Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other information held by Google.
We may also use additional analytics programs, such as Amazon Web Services or Microsoft Azure, from time to time to process non-personal information about you.
We make no attempt to link this non-personal information with the identity of individuals using the Service. Non-personal information may be permanently archived for future use in any manner whatsoever by Delphi.
Disable Google Analytics
You can prevent the collection and processing of cookie created data relating to your utilization of the Service (including your IP) via Google by downloading and installing the browser-plugin available under the following link (https://tools.google.com/dlpage/gaoptout?hl=en).
Google currently offers this opt-out tool for Internet Explorer 11, Google Chrome, Mozilla Firefox, Apple Safari and Opera.
Further information concerning the terms and conditions of Google’s use and data privacy can be found at https://www.google.com/analytics/terms/us.html or at https://policies.google.com/privacy.
17. Contact Us
Delphi Privacy Officer
Mailing Address: 2-25 Scurfield Blvd, Winnipeg MB R3Y 1G4
Telephone No.: 431-668-8886
19. Withdrawing Consent
You may withdraw your consent to the collection, use or disclosure of your personal information by Delphi at any time, subject to legal or contractual restrictions and reasonable notice. In certain circumstances, your withdrawal of consent may result in the inability of Delphi to continue providing aspects or optimization of the Service to you. Please contact Delphi for more information regarding the implications of withdrawing consent.
20. Unsubscribe from Commercial Electronic Messages
We may send you commercial electronic messages (such as marketing or promotional messages) if you have:
- provided us with your express consent to receive these messages;
- recently purchased or leased a product or service from us;
- entered into a contract with us or some other form of business relationship with us;
- requested information from us; or
- applicable law otherwise permits us to send commercial electronic messages to you.
If you no longer wish to receive commercial electronic messages from Delphi regarding our new products or services, promotions or other similar communications, you may unsubscribe here. Please note that, after you unsubscribe, Delphi may still send electronic communications to you in certain limited circumstances, such as to provide you with Service notifications and billing information, or to provide information that Delphi is legally obligated to provide you.
Date: February 10th, 2021.