Viral Nation Privacy Policy

Last updated: March 14, 2022

At Viral Nation Inc. (“Viral Nation”) we are committed to maintaining the accuracy, confidentiality and security of your personal information in accordance with applicable laws. This Privacy Policy describes the personal information that Viral Nation collects from or about you, how we use and to whom we disclose that information when you use our website, and use our products or services, including but not limited to our VN Secure software-as-a-service-solution (collectively, “Services”). The rights and obligations contained in this Privacy Policy may not be available to all individuals or in all jurisdictions. If you are unsure if or how this Privacy Policy applies to you, please contact our Privacy Officer.

What is Personal Information?

For the purposes of this Privacy Policy, “personal information” is any information about an identifiable individual, other than the person’s business title or business contact information, when used or disclosed for the purpose of business communications.

What Personal Information Do We Collect?

We may collect and maintain different types of personal information in respect to the individuals with whom we interact. This includes:

  1. Personal Data that you submit to us or for which you authorize our collection, including contact information (first and last name, address, postal code, email address, and telephone number);
  2. Social Media Profile Data including account names, photos, videos, likenesses, and written or audio comments and submissions made on social media platforms;
  3. Demographic Data including gender and age;
  4. Inferences to create a profile about your characteristics, habits, and lifestyle, in accordance with you or an authorized user’s instructions or selections made through our Services; and
  5. Technical Data including internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website; and
  6. Marketing and Communications Data including your preferences in receiving marketing and communications from us and our third parties.

Viral Nation may collect personal information directly from you or from a third party to whom you have given consent to provide the information to us for the purposes as described in this Privacy Policy. In particular, third parties may disclose your personal information to us in the course of obtaining Services from us. Where this is the case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us.

IF YOU BELIEVE THAT YOUR PERSONAL INFORMATION WAS COLLECTED, USED BY, OR DISCLOSED TO US WITHOUT YOUR CONSENT, PLEASE CONTACT OUR PRIVACY OFFICER.  

In addition to the above, any information we collect or that you provide directly to us may be de-identified or anonymized to protect your information.

From time to time, where permitted or required by applicable law or regulatory requirements, we may collect information about you without your knowledge or consent.

Why Do We Collect Personal Information? 

Viral Nation collects personal information to enable us to manage, maintain, and develop our business and operations, including:

  1. to facilitate your or an authorized user’s use of the Services in accordance with our Terms of Service;
  2. to be able to comply with your requests;
  3. to protect us against error, fraud, theft and damage to our goods and property;
  4. to enable us to comply with applicable law or regulatory requirements; and
  5. any other reasonable purpose to which you consent.

Our third-party service providers may require certain information, technology and data, and services from us from time to time so that we may operate our business. As a result, your personal information may be collected, used, processed, stored or disclosed in accordance with Canadian law. Under the laws of other jurisdictions, in certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in other jurisdictions may be entitled to access your personal information.

When Do We Disclose Your Personal Information? 

We may share your personal information with our affiliates, employees, contractors, consultants, and other parties who require such information to assist us with managing our relationship with you, including: third parties that provide services to us or on our behalf; third parties that assist Viral Nation in the provision of services to you; and third parties whose services we use to conduct our business.

Further, your personal information may be disclosed:

  1. as permitted or required by applicable law or regulatory requirements;
  2. to comply with valid legal processes such as search warrants, subpoenas or court orders;
  3. to protect the rights and property of Viral Nation;
  4. during emergency situations or where necessary to protect the safety of a person or group of persons; or
  5. with your consent.

Cookies

Cookies are files with a small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web site and transferred to your device.

For visitors to our Website, we use cookies to collect information in order to perform and improve our Website and Services. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. The “Help” feature on most browsers provides information on how to accept cookies, disable cookies or to notify you when receiving a new cookie. If you do not accept cookies, you may not be able to use some features of our Website or Services and we recommend that you leave them turned on.

Your Consent is Important to Us

It is important to us that we collect, use or disclose your personal information where we have your consent to do so. Depending on the sensitivity of the personal information, your consent may be implied, deemed (using an opt-out mechanism) or expressed. Express consent can be given orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from your action or inaction. If we plan to use or disclose your personal information for a purpose not previously identified (either in this Privacy Policy or separately), we will endeavor to advise you of that purpose before such use or disclosure.

As we have described above, 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 or regulatory requirements.

Choice/Opt-Out

You may change or withdraw your consent at any time, subject to legal or contractual obligations and reasonable notice, by contacting our Privacy Officer using the contact information set out below. All communications with respect to such withdrawal or variation of consent should be in writing and addressed to our Privacy Officer.

We assume that, unless you advise us otherwise, that you have consented to the collection, use and disclosure of your personal information as explained in this Privacy Policy.

How is Your Personal Information Protected?

Viral Nation endeavors to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to prevent your personal information from loss and unauthorized access, copying, use, modification or disclosure.

The security of your personal information is important to us, please advise our Privacy Officer immediately of any incident involving the loss of or unauthorized access to or disclosure of personal information that is in our custody or control.

Updating Your Personal Information

It is important that the information contained in our records is both accurate and current. If your personal information happens to change during the course of our relationship, please keep us informed of such changes.

In some circumstances we may not agree with your request to change your personal information and will instead append an alternative text to the record in question.

Access to Your Personal Information

You can ask to see or delete your personal information. If you want to review, verify, correct or request deletion of your personal information, please contact our Privacy Officer. Please note that any such communication must be in writing (including electronically).

When requesting access to or deletion of your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access or deletion, as well as to search for and provide you with the personal information that we hold about you. If you require assistance in preparing your request, please contact the office of our Privacy Officer.

Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices.

In the event that we cannot provide you with access to your personal information, we will endeavor to inform you of the reasons why, subject to any legal or regulatory restrictions.

Inquiries or Concerns

If you have any questions about this Privacy Policy or concerns about how we manage your personal information, please contact our Privacy Officerl. We will endeavor to answer your questions and advise you of any steps taken to address the issues raised by you. If you are dissatisfied with our response, you may be entitled to make a written submission to the Privacy Commissioner in your jurisdiction.

Privacy Officer

We have appointed a Privacy Officer to oversee compliance with this Privacy Policy. The contact information for our Privacy Officer is as follows:

Manny Kandola, Chief Technical Officer

Revisions to this Privacy Policy

From time to time, we may make changes to this Privacy Policy to reflect changes in its legal or regulatory obligations or in the manner in which we deal with your personal information. We will post any revised version of this Privacy Policy on our website and we encourage you to refer back to it on a regular basis.

Interpretation of this Privacy Policy

Any interpretation associated with this Privacy Policy will be made by our Privacy Officer. This Privacy Policy includes examples but is not intended to be restricted in its application to such examples; therefore, where the word ‘including’ is used, it shall mean ‘including without limitation’.

This Privacy Policy does not create or confer upon any individual any rights, or impose upon Viral Nation any obligations outside of, or in addition to, any rights or obligations imposed by Canada’s federal and provincial privacy laws, as applicable. Should there be, in a specific case, any inconsistency between this Privacy Policy and Canada’s federal and provincial privacy laws, as applicable, this Privacy Policy shall be interpreted, in respect of that case, to give effect to, and comply with, such privacy laws.