Last Updated: July 27, 2022
I. COLLECTION AND USE OF PERSONAL INFORMATION
While using our Website and Services, we may ask you to provide us with certain Personal Information, including but not limited to:
- Personal Information We Collect From Our Customers. We may collect certain Personal Information from you, including but not limited to the following: (i) name; (ii) email address; (iii) phone number; (iv) company information; and (v) payment information.
- Personal Information Contained In Documents Provided To Us For Processing Via Our Services. Our Services are generally designed to assess and remediate accessibility compliance issues in documents and digital properties. Our expectation is that documents that you submit to us will be public-facing documents and will not contain any Personal Information (and will not contain any sensitive Personal Information such as personal health information or personal financial information). Accordingly, please do not submit documents containing any Personal Information to us for processing via our Services without first contacting us and obtaining our written approval to the processing of such documents via our Services.
- Device Information. We may collect information about devices you use to access our Website and information about how you use our Website, such as your IP address and which websites you visited before accessing our Website.
- Log Data. Our servers automatically record information created by your use of our Services to help us diagnose and fix technical issues, and to improve the overall quality and user experience of our Services. This may include information such as your IP address, browser type, browser version, operating system, details of how you used our Services (such as the functions you asked our Services to perform), diagnostic information related to the Services (such as crash activity reports), the referring web page, the time and date of your visit, the pages visited, the time spent on those page, location, your device and application IDs, and search terms.
- Cookies. A cookie is a small text file containing a unique identifier that is placed on your computer’s hard drive when you visit a website. We use technologies like cookies and pixel tags to gather information about how you are interacting with our Website or our Services, which may include identifying your IP address, browser type, and referring page. If you choose to decline cookies, you may not be able to experience the entire features of the Website.
- Employee and Contractor Candidate Information. When we seek candidates for potential jobs or contracting engagements, we collect information from those candidates who apply, which may include contact information, education and employment history, credentials, place of residence and other information the candidate believes to be relevant. For people who become our employees or contractors, we will typically retain the information provided by those candidates in the application process along with additional information to manage their employment or contractor relationship with us, including, without limitation, banking or other payment information (for payment of salaries, consulting fees or other remuneration), information related to income tax reporting and withholding and enrollment in Allyant’s benefit plans (in each case, to the extent applicable for the relevant relationship).
- Marketing Information. Our Website contains electronic forms that allow visitors to submit contact information (name, email address, phone number and physical address (including country)) for the purposes of submitting sales inquiries and/or receiving marketing materials from us. From time to time, we may conduct surveys or hold contests or other events or attend industry conferences and, in connection with such surveys, contests, events or conferences, we may collect information you elect to provide about yourself, such as your name, email address, telephone number, organization name and address; and general information about the company for whom you work. In addition, we may use third-party service providers to collected business-related information about your employer such as its name, size, and publicly available revenue in connection with potentially offering our Products and/or Services to your employer.
If you wish to stop receiving email communications from us, you may opt-out of receiving such communications by clicking the “Unsubscribe” link at the bottom of the email.
We use the Personal Information collected from you listed above for the following reasons:
- To conduct and fulfill business and contractual relationships that we have with various persons and companies (such as customers, suppliers, resale channels and employees);
- To verify identities for the purposes of complying with know-your-customer laws and regulations, economic sanctions laws and regulations and other similar laws and regulations;
- To provide, operate, maintain and improve our Website and/or Services;
- To send technical notices, updates, security alerts and support and administrative messages;
- To respond to comments, questions, and requests and provide customer service and support;
- To communicate with you and provide news, marketing or promotional materials, or other information about us;
- To investigate and prevent fraudulent transactions, unauthorized access to the Services, and other illegal activities;
- To process any responses to employment opportunities;
- To monitor and analyze trends, usage, and activities in connection with the Website and/or Services, including generating aggregated and anonymized statistics; and
- for other purposes which we will notify you about and seek your consent.
We do not collect Personal Information for the purpose of selling your Personal Information to third parties.
II. DISCLOSURE OF PERSONAL INFORMATION TO THIRD PARTIES
We may share your Personal Information with the following third parties for the following reasons:
- Service Providers and Business Partners. We may from time to time employ third parties to perform tasks for us and we may need to share Personal Information with them to perform those tasks. Unless we tell you differently, such third parties do not have any right to use the Personal Information we share with them beyond what is necessary for them to perform the relevant tasks for us that we have allocated to them. The third parties we currently engage include third-party companies and individuals employed or contracted by us to provide certain capabilities in respect to the Website and/or Services and for certain general business functions, including the provision of database management, payment processing and customer relationship management tools.
- As Required by Law. We may disclose your Personal Information to third parties without your consent if we have reason to believe that disclosing this information is necessary to identify, contact, or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other users, or anyone else (including the rights or property of anyone else) that could be harmed by such activities. We may also disclose your Personal Information to third parties without your consent to prevent damage to property, bodily injury and/or death. Further, we may disclose Personal Information when we believe in good faith that such disclosure is required by and in accordance with the law, such as to satisfy any applicable law, regulation, legal process or governmental request (including a subpoenas, civil investigative demand, or similar process); enforce our contracts or user agreements, including investigation of potential violations thereof; and/or detect, prevent, or otherwise address fraud, security, or technical issues.
III.STORAGE LOCATION AND TRANSFER OF PERSONAL INFORMATION
Our Services are hosted in the United States and/or Canada and we process and store any data, including your Personal Information, on servers located in the United States and/or Canada. By visiting our Website and using our Services, you agree to the transferring, storing, and/or processing of your Personal Information in the United States and Canada, where laws regarding processing of Personal Information may be less stringent than the laws in your country. By providing your Personal Information, you consent to such transfers. If you are in the U.K., Switzerland, or the European Economic Area (“EEA”), please see the additional specific terms below which apply to you.
IV. YOUR PRIVACY RIGHTS
A. EUROPEAN ECONOMIC AREA (“EEA”) AND UK PRIVACY RIGHTS
If you are a resident of the EEA, the U.K., or Switzerland, you have certain data protection rights. We will take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Information (known as “Personal Data” under the EU General Data Protection Regulation and under the UK Data Protection Act 2018 and the UK GDPR and the Swiss Federal Act on Data Protection).
- where the processing is necessary for the purpose of legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the applicable data subject and require the protection of such Personal Data. Specifically, we process Personal Data of personnel employed by or retained as contractors by entities with whom we have the legitimate interest of entering into contracts or the legitimate interest of performing contracts;
- where the processing is necessary for compliance with a legal obligation applicable to us;
- where the processing is necessary to protect the vital interest of the data subject or another natural person; and
- where the applicable data subject has given consent to the processing of his or her personal data.
In certain circumstances, you have the following data protection rights, subject to applicable limitations:
- The right to request access to your Personal Data (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Data we hold about you where we are the data controller and to check that we are lawfully processing it.
- The right to request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us.
- The right to request erasure of your Personal Data. This right allows you to ask us to delete or remove Personal Data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your erasure request for specific legal reasons which we will tell you when responding to your request.
- The right to request object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- The right to request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios: (a) if you want us to establish the information’s accuracy; (b) where our use of the information is unlawful but you do not want us to erase it; (c) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.
- The right to request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- The right to request withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdrew your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time we respond to your request.
If you would like to exercise any of these rights, please contact us as set forth below. We will process such requests in accordance with applicable laws. To protect your privacy, we take steps to verify your identity before fulfilling your request to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
B. CALIFORNIA CONSUMER PRIVACY ACT (“CCPA”)
This section provides information regarding California residents’ rights regarding their Personal Information afforded under the CCPA. For specific details regarding the Personal Information that we have collected about you over the last 12 months and the purposes for collecting such information, please refer to the section “Collection and Use of Personal Information” noted above. We do not sell (as that term is defined in the CCPA) any Personal Information collected from you.
Subject to certain limitations, the CCPA provides California residents several rights: (i) the right to request disclosure of information collected and shared about them; (ii) the right to delete their information; (iii) the right to opt-out of any sale of your Personal Information; and (iv) the right to not be discriminated against for exercising any of these rights. You may exercise any of these rights by contacting us as set forth below. We will ask you to provide identifying information or use the Personal Information associated with your account, if available, to verify your request, or you may designate an agent to submit a request on your behalf.
V. ACCESS, CORRECTION AND ACCURACY
You have the right to access the Personal Information we hold about you in order to verify the Personal Information we have collected about you and to receive a general account of our uses of that Personal Information. Upon receipt of your written request, we will provide you with a copy of your Personal Information, although in certain limited circumstances, and as permitted under law, we may not be able to make all relevant Personal Information available to you, such as where that Personal Information also pertains to another individual. In such circumstances we will provide reasons for the denial to you upon request. We will endeavor to deal with all requests for access to and modifications of Personal Information in a timely manner.
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, this amended Personal Information will be transmitted to those parties to which we are permitted to disclose your Personal Information.
VI. DATA RETENTION
VII. SECURITY OF YOUR INFORMATION
VIII. CHILDREN’S INFORMATION
Our Services are intended for business use and are not intended for children under 13 (or other age as required by local law), and we do not knowingly collect Personal Information from children. We do not sell Personal Information, including the Personal Information of children under 13 years of age. If a child under 13 submits Personal Information to us and we learn that we have collected any Personal Information of a child under 13, we will promptly take steps to delete such Personal Information and terminate the child’s account as soon as possible. If you believe that we may have collected Personal Information from a child under 13, please contact us as set forth below.
IX. THIRD-PARTY WEBSITES
Our Services may contain links to websites and services that are owned or operated by third parties, which may include features that collect your IP address, which page you are visiting on our Services, and may set up a cookie to enable the links to function properly. Any information that you provide on such sites is provided directly to such third parties and are governed by their respective privacy practices and policies. We are not responsible for their respective content, privacy or security practices and policies. To protect your information, we recommend that you carefully review the privacy policies of all third-party websites that you access. Our Services may include access to publicly accessible blogs, forums, or social media pages. Personal information you voluntarily transmit or publish online in such publicly accessible blog, forum, or social media page may be viewed and used by others without any restrictions.
XI. CONTACT INFORMATION
Attention: Chief Information Officer
885 Meadowlands Drive East, Suite 401
Ottawa, Ontario, Canada
Toll Free: 1 800 563 0668
1The affiliated companies include, but are not limited to, T-Base Communications L.P., T-Base Communications Holdings, Inc., T-Base Communications USA Inc., A360 Enterprises, LLC, NetCentric Technologies Inc., NetCentric Egypt (LLC), T-Base Holdings Inc., T-Base Communications Inc., NetCentric Australia Pty Ltd.