This Privacy Policy (“Policy”) describes the personal information that LlamaZOO Interactive Inc. (“LlamaZOO”, “we”, “us” or “our”) collects from or about you when you use LlamaZOO’s software products and software-as-a-service solutions (the “Services”), how we use that information, and to whom we disclose it. “Personal information” means any information that identifies a user as an individual or is reasonably capable of doing so in combination with other available information.

Please read this Policy carefully. If you do not agree with this Policy, you should not access or use the Services or provide us with your personal information. This Policy should be read in conjunction with the LlamaZOO End User License Agreement, into which it is incorporated by reference.

This Policy was last updated on February 3, 2020. We may modify this Policy from time to time. We will provide you with notice of any material changes to this Policy by publishing or communicating the changes through our Services or by other means so that you may review and comment on the changes before continuing to use our Services. Your continued use of the Services after we publish or communicate a notice about any changes to this Policy means that you are consenting to the changes.

1. Accountability and Openness / Compliance
LlamaZOO is responsible for personal information under our control. We have established policies and procedures to effectively safeguard any confidential personal information that we collect, and to deal with complaints and inquiries. We are committed to maintaining the accuracy, confidentiality and security of your personal information, and we will ensure that you have access to information regarding the policies and procedures that we use to manage your personal information.

LlamaZOO has designated a privacy officer (“Privacy Officer”) who is accountable for our compliance with this Policy, and for ensuring that information about our policies and practices relating to the management of personal information is easily accessible. All questions or concerns regarding this Policy and our compliance with it should be directed to the Privacy Officer in writing, and sent by email to privacy@llamazoo.com or by mail to:

Privacy Officer
LlamaZOO Interactive Inc.
200-1019 Wharf St
Victoria BC
V8W 2Y9
Canada

Every complaint or challenge regarding our compliance with this Policy will be investigated, and where a deficiency is found to exist, we will take appropriate measures to address it. This may include amending our policies and procedures as necessary. We will also cooperate with regulatory authorities to resolve any complaints that cannot be resolved between us and an individual user.

If you are located in British Columbia, you may contact the Office of the Information & Privacy Commissioner for British Columbia at P.O. Box 9038 Stn. Prov. Govt., Victoria, B.C. V8W 9A4 or https://www.oipc.bc.ca with any complaints regarding this Policy. Users may also contact the Office of the Privacy Commissioner of Canada at 30 Victoria Street, Gatineau, Quebec K1A 1H3 or https://www.priv.gc.ca/.

2. Consent
By using the Services, you signify your agreement to the terms and conditions of this Policy and to our collection, use and disclosure of your personal information as set out herein. You may change or withdraw your consent to the collection, use or disclosure of your personal information at any time by contacting the Privacy Officer in writing at the address listed above (see: Accountability and Openness / Compliance). In some circumstances, a change or withdrawal of consent may affect your ability to use the Services.

3. Collection and Retention of Information
We collect Personal Information only to the extent that it is necessary for the purposes set out below (see: Purpose – Why We Collect, Use and Disclose Information).

Subject to any legal or accounting requirements, we will retain personal information only as long as necessary to fulfill the purposes for which it was collected. Personal information that is no longer required will be destroyed, erased or made anonymous, although copies of deleted information may continue to exist on back-up media.

Information that we may collect includes:

• User Information
  We collect certain personal information associated with the creation and maintenance of user accounts, including a user’s name, e-mail address and other contact information. We also collect information generated through a user’s use of the Services, including a user’s progress reviewing or marking-up content.
• Usage Data
  We collect certain non-identifying information about usage of the Services, including information about how users are using the Services and the characteristics of those users. This information is anonymized and is not used by us to identify you as an individual.
• Technical and Device Information
  We collect certain non-identifying information related to a user’s access of the Services, including the Internet Protocol (IP) address of the user’s computer, the date and time the user accessed the Services, and the operating system that the user is using. We make no attempt to link this information with the identity of individuals visiting our website without express permission. We may, however, review server logs and anonymous traffic for system administration and security purposes, for example to detect intrusions into our network, for planning and improving web services, and to monitor and compile statistics about website usage. The possibility therefore exists that server log data, which contains users’ IP addresses, could in instances of criminal malfeasance be used to trace and identify individuals. In such instances, we may share raw data logs with the appropriate authorities for the purpose of investigating security breaches.

4. Purpose – Why We Collect, Use and Disclose Information
We will identify the purposes for which we collect personal information before or when we request the information. We will not collect personal information which is not necessary and, except as specified below, will not use or disclose personal information for any purpose other than the purpose(s) for which it was collected without first obtaining your consent. The information that we collect is used and disclosed only for business purposes. These include:

• to open and maintain user accounts;
• to process, track and communicate with you about usage of the Services;
• to establish, maintain and manage business relations with you so that we may provide you with the information, products or services that you request;
• internal business purposes, such as administering or improving the Services;
• to perform internal market research and conduct polls and surveys;
• to obtain feedback regarding the Services and our ability to address a user’s needs;
• to provide users with information and promotional materials regarding LlamaZOO and LlamaZOO’s products and services;
• to protect us against error, fraud, theft or damage to our goods, our business or our property;
• to comply with any legal, accounting and regulatory requirements, including reporting requirements, applicable laws, and any search warrants, subpoenas or court orders; and
• any other reasonable purpose for which you provide consent.

We may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required to do so by applicable law, government request or court order, or based on our good faith belief that it is necessary to do so in order to comply with such law, request or court order, or to protect our assets, the users of our website, or the public.

5. Disclosure to Third Parties
We may disclose your personal information in response to requests from government agencies, law enforcement authorities and regulators, or to satisfy legal or regulatory requirements. We may also disclose your personal information when we buy a business or sell all or part of our business.

You further acknowledge and agree that, in the course of providing the Services to you, we may delegate our authority to collect, access, use, and disseminate your information to third party subcontractors. Third party subcontractors may include web hosts, payment processors, delivery and logistics providers, social network integrators, and membership vendors. If we transfer any personal information to a third party subcontractor, we will provide the subcontractors only with the information needed to perform the subcontracted service, and will use appropriate contractual or other means to provide a comparable level of protection while the information is being used by them.

6. Safeguards – How Information is Protected
We maintain reasonable security safeguards to protect personal information in our possession or under our control from loss or theft, and from unauthorized access, disclosure, copying, use or modification, regardless of the format in which the information is held. The safeguards applied will depend on the sensitivity of the personal information, with the highest level of protection given to the most sensitive personal information. We use user IDs, passwords, and encryption technology, maintain our paper files in locked premises, and restrict the employees and contractors who have access to personal information to those having a “need to know” and who are bound by confidentiality obligations in order to ensure that information is handled and stored in a confidential and secure manner. When destroying personal information, we delete electronically stored personal information and shred any tangible materials containing personal information. While we will endeavour to destroy all copies of personal information, you acknowledge that deleted information may continue to exist on back-up media but will not be used unless permitted by law.

We will continually review and update our security policies and controls as technology evolves. However, no security technology can be guaranteed to be failsafe. Using the Internet or other public means of communication to collect and process personal data may involve the transmission of data on an international basis and across networks not owned and/or operated by us. Therefore, by using the Services and/or communicating electronically with us, you acknowledge and agree to our processing of personal information in this way and agree that we are not responsible for any personal information which is lost, or which is altered, intercepted or stored by a third party without authorization.

7. Accuracy / Access
LlamaZOO has a responsibility to ensure that all personal information contained in our records or which is disclosed to third parties for the purposes described above is accurate, complete and up-to-date. You may make a request in writing for access to your personal information. We will inform you of your personal information held by us, and provide an account of the use that has been made of the information, as well as identify any third parties to whom the information has been disclosed. You may have reasonable access to your personal information, and if you demonstrate the inaccuracy or incompleteness of personal information, the information will be amended as appropriate. You should advise us immediately if you discover inaccuracies in our data, if your personal information changes, or if you wish to have your information removed from our files. All notices and requests should be in writing and sent to the Privacy Officer at the address listed above (see: Accountability and Openness / Compliance).

8. International Transfer and Storage of Information
You acknowledge and agree that your personal information may be transmitted, transferred, processed, and/or stored outside of Canada, including in the United States, and therefore may be available to governmental authorities under lawful orders and laws applicable in such jurisdictions. We will use reasonable means to ensure that your information is protected, but cannot guarantee that the laws of any foreign jurisdiction will accord the same degree of protection as the laws of Canada.

9. Third Party Content and Links to other Websites
The Services may contain optional links to third party Internet websites and services. You acknowledge that these third parties may collect data from users or their computers. The accessing and use of third party websites or services is at your own risk, and we cannot assume responsibility for the privacy practices, policies or actions of the third parties who operate those websites or services. This Policy applies only to the LlamaZOO Services, and we encourage you to review the privacy policies of any third parties when using their websites or services.

10. Minors
Minors (persons under the age of majority as defined in your jurisdiction) are not eligible to use the Services unsupervised, and we request that minors do not submit any personal information to us. If you are under the age of majority in your jurisdiction, you may only use the Services in conjunction with and under the supervision of an adult. LlamaZOO does not knowingly collect personal information from minors.

11. Governing Law
You agree that your access to and use of the Services, as well as this Policy, is governed exclusively by the laws of the Province of British Columbia and the federal laws of Canada applicable therein (excluding conflicts or choice of laws principles).