SANDBOX CENTRE FOR SHARED
ENTREPRENEURSHIP & INNOVATION
PRIVACY POLICY
At the Sandbox Centre for Shared Entrepreneurship & Innovation (the “Sandbox Centre”), we are dedicated to protecting your privacy and safeguarding the personal, business, and financial information (the “Information”) entrusted to us. That commitment is fundamental to the way we do business and is reflected in our policies.
The Sandbox Centre follows a comprehensive set of privacy policies and security practices in compliance with laws and to support our commitment of trust through integrity in everything we do. This Policy describes how we collect and use your Information, and governs how that Information may be shared and with whom.
This policy is made pursuant to the Personal Information Protection and Electronic Documents Act (PIPEDA) and the Privacy Act. We collect personal information about individuals as defined by section 3 of the Privacy Act. As guardian of the privacy rights of individuals in Canada under the Privacy Act and PIPEDA, we are committed to respecting the privacy rights of all individuals whose personal information has been collected by us.
Accountability – Privacy Officer
The Sandbox Centre has a Privacy Officer who is responsible for overall privacy governance. All of our employees across the Sandbox Centre are responsible for maintaining your privacy and are available to address any questions or concerns that you may have.
If you have questions regarding privacy, please contact us at:
The Sandbox Centre
24 Maple Avenue, 2nd Floor
Barrie, Ontario, Canada, L4N 1R7
Attention: Chris Mazzone
1-705-896-2900
The Information We Collect
Most of the Information we collect is directly from you when you sign in to the Sandbox Centre or when you sign up to utilize our services or the services of others within the Sandbox Centre (the “Services”).
We only request and collect the Information that enables us to assist you or to provide better Services.
Information essential for fulfilling our Services includes:
- Information establishing your identity, such as your name, address, phone number, title, business phone number, and email address.
- Information pertaining to your business, including your business name, address, phone number, email address, and industry type. Providing us with your information is always your choice.
We use your Information in order to:
- Verify your identity;
- Provide you with the Services;
- Communicate to you any benefit, feature and/or other information about the Services;
- Respond to any special needs or inquiries you may have;
- Manage our risks and operations;
- Process any payment which might be due, where applicable; and
- Meet regulatory and legal requirements.
The Sandbox Centre may use your Information for secondary purposes such as:
- Telling you about new services at the Sandbox Centre.
- Inviting you to participate in customer surveys or other opinion-gathering devices.
- Providing you with special offers from other companies made available to Sandbox Centre customers.
- Telling you about educational events, such as training seminars, conferences and online training sessions.
- Sharing the Information with our Partners in order to make your interaction with them as seamless as possible (see below for more information on this).
User Activity and Cookies
The Sandbox Centre uses HubSpot CRM to understand our users’ behavior. We may also utilize web sites, mobile applications or other interactive services (the “Sites”). When you visit our Sites, we may collect certain information by automated means, such as cookies. The information we collect in this manner includes IP address, browser characteristics, device characteristics, operating system, language preferences, referring URLs, information on actions taken on our Sites, and dates and times of visits to the Sites. By collecting this information, we can better understand activity on our Sites and learn how to best tailor our Sites to our visitors. While we generally examine such information only in the aggregate, such information could be linked back to individual IP addresses or other information about you.
A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. We use two kinds of cookies on the Sites: session cookies and persistent cookies. Session cookies exist only for as long as your browser remains open. Once you exit your browser, they disappear. Persistent cookies, in contrast, last from visit to visit; they remain on your hard drive after you exit your browser. The cookies used on the Sites include those which are strictly necessary cookies for access and navigation, cookies that track usage (performance cookies), and remember your choices (functionality cookies. Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. Please note, however, that without cookies, you may not be able to use all of the features of our Sites.
We may use the information we obtain from your use of our cookies for the following purposes:
- to recognize your computer when you visit the Sites;
- to track you as you navigate the Sites, and to enable the use of any e-commerce facilities;
- to improve the Sites’ usability;
- to analyze the use of the Sites; and
- in the administration of the Sites.
Device-Specific Data
The following information may be collected through your device and browser:
- your device’s IP address (collected and stored in an anonymized format)
- device screen size
- device type (unique device identifiers) and browser information
- geographic location (country only)
- preferred language used to display the webpage.
Log Data
Our servers automatically record information which is created upon using HubSpot CRM. Data includes:
- referring domain
- pages visited
- geographic location (country only)
- preferred language used to display the webpage
- date and time when website pages were accessed
Logged Data Collected may also include:
- IP address
- Device identifiers
- Web browser information
- Page view statistics
- Usage information, including events that take place within the platform
- Log data (e.g. access times, hardware and software information)
We process Personal Data to operate, improve, understand and personalize our Services. For example, we use Personal Data to:
- Create and manage user profiles
- Communicate with you about the Services
- Contact you about Service announcements, updates or offers
- Provide support and assistance for the Services
- Personalize application content and communications based on your preferences
- Meet contract or legal obligations
- Respond to user inquiries
- Fulfill user requests
- Resolve disputes
- Protect against or deter fraudulent, illegal or harmful actions
- Enforce our Terms of Service
We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.
Additional Uses
We may communicate with you through various channels including telephone, computer or mail using the contact information you have provided.
You agree that, by providing your email address, you consent to receive electronic communications in respect of the Services. You may withdraw this consent at any time, in accordance with the procedure below.
If for any reason your information is required to fulfill a different purpose than that of your original intent, we will ask for your consent before we proceed.
IMPORTANT ACKNOWLEDGEMENT ABOUT YOUR PRIVACY AND THE DATA WE COLLECT:
Please note, some of the basic information given in this system will be shared across the Business Ecosystem in Central Ontario. This currently includes the Sandbox Centre, the Georgian College, Henry Bernick Entrepreneurship Centre, the Small Business Centre and the local Community Futures Development Corporations but could be expanded to include other partners (the “Partners”). The information is shared to ensure your needs a being met as a business owner/member in our community.
Our Employees
Access to your information is restricted to authorized employees who have a legitimate business purpose for accessing it. For example, when you call us or email us, designated employees will access your information to verify that you are the account-holder and to assist you in fulfilling your requests.
Unauthorized access to and/or disclosure of client information by an employee of the Sandbox Centre is strictly prohibited. All employees are required to maintain the confidentiality of client information at all times and failing to do so will result in appropriate disciplinary measures, which may include dismissal.
Keeping Your Information Safe
Ensuring your confidentiality by protecting your personal and business information is fundamental to the way we do business. For more information see our security statement.
Keeping Your Information Accurate
We do the utmost to ensure the information we have about you is accurate and complete. We encourage you to help us keep our information current. Contact us at any time if you wish to verify the accuracy or update the information we have about you.
Your Right to Access Your Personal Information
In the normal course of business, you receive periodic access to information in the form of transaction activity records, including account statements and order confirmations. This information is routinely available to you through emails and our secure online website.
If you want to verify the accuracy of other personal information we hold about you, you may submit a written request to our privacy officer noted above to obtain access to such information. To avoid delays in obtaining your information, please provide enough detail to permit us to identify you and the specific information that you are requesting.
If you believe that there is a mistake in the information that we have collected, you have the right to ask for it to be corrected. We may ask you to provide evidence that our records are wrong. When we agree that we have made a mistake, we will correct that mistake and notify anyone to whom we sent the incorrect information. If we do not agree that we have made a mistake, we will still agree to include in our file a brief statement from you on the point and we will forward that statement to anyone else who received the earlier information.
CAN SPAM Act
The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.
We collect your email address in order to:
- Send information, respond to inquiries, and/or other requests or questions
- Send you additional information related to the Services
To be in accordance with CAN-SPAM, we agree to the following:
- Not to use false or misleading subjects or email addresses.
- To identify the message as an advertisement in some reasonable way.
- To include the physical address of our business or site headquarters.
- To monitor third-party email marketing services for compliance, if one is used.
- To allow users to unsubscribe by using the link at the bottom of each email.
- To honor opt-out/unsubscribe requests quickly.
If at any time you would like to unsubscribe from receiving future emails, you can follow the instructions at the bottom of each email and we will promptly remove you from ALL correspondence.
Questions?
If you have any questions about our privacy policies and how they relate to you, please contact us.