Posted: April 13, 2023
Effective: April 30, 2023
Galactic Propeller Holdings Ltd., doing business as Squaredance (“Squaredance” or "we" or “us” or “our”) operates the website www.squaredance.io (“Website”) and provides access to our Squaredance Platform (“Platform”) to our business customers (“Customers” or "customers").
1. "Personal Information"
"Personal information" is broadly defined as any information about an identifiable individual. In general, personal information does not include business contact information, including your name, title or position, business or business email address, telephone or facsimile number.
We are responsible under applicable privacy legislation for the personal information in our possession or control. This includes personal information we receive directly, such as from individual customers or other individuals, and personal information we receive indirectly from customers or others. We have established policies and procedures with the objective of protecting personal information and have appointed Privacy Officers to oversee privacy matters for our company. Our Privacy Officers can be reached at [email protected]
3. What Personal Information Do We Collect?
The types of personal information we may collect about you include your name and contact information, billing and account information, information relevant to your or a Customer or User’s use of the services on the Platform or Squaredance Website and other information incidental to the provision of services by Squaredance.
4. Our Purposes for Collecting, Using or Disclosing Personal Information
We collect, use and disclose personal information for the following purposes:
- to establish and manage client relationships and to perform services;
- to represent clients in the context of business transactions involving the exchange or disclosure of personal information;
- to establish and maintain commercial relationships with clients, suppliers and other third parties, including to issue invoices, administer accounts, collect and process payments, evaluate credit standing, and to fulfill contractual obligations;
- to distribute our publications and invitations to events to individuals who subscribe to our mailing lists;
- to develop and manage our business and operations;
- to detect and protect against error, negligence, breach of contract, fraud, theft and other illegal activity;
- as permitted by, and to comply with, applicable legal or regulatory requirements or provisions;
- to identify products and services which will meet your needs;
- to consolidate and analyze on a non-individualized basis demographic information for our own use or for other party’s use in developing marketing platforms and services; and
- to promote to you other products and services offered by us or an affiliate or subsidiary of ours.
You acknowledge and agree to our collection, use and disclosure of personal information for the above purposes.
Publications and Newsletters
Any publications or newsletters use the contact information for those who subscribe through our Website, Platform or by invitation by us. Our publications and newsletters draw on a contact database of primarily business contacts that may also include individuals. We provide an opportunity to any contact to unsubscribe from our publications program on an ongoing basis at any time by contacting us.
- Signup and Request for Proposal - For the purposes of using our services, you may voluntarily submit personal information to us for the purposes of becoming a vendor or supplier of Squaredance. We use this personal information you provide only for the purpose for which you have provided it.
- Careers and Employment - Our Website may provide links for individuals to submit applications for jobs at Squaredance. These may link to third-party applications, such as a Human Resource Information System software or application, which we may use from time to time. We use any personal information you provide during this application process only for the purpose for which you have provided it, ie. for employment consideration.
As further described and defined in the GTOS, non-confidential and non-personally identifiable User Data, such as sales data and information, pricing, and other similar information, customer analytics, and other data generated by or collected from Users, Authorized Members and End-Customers, may be used by Squaredance to provide the Platform services, enhance the Platform, collect and deliver market insights, and for other business purposes.
Aggregate Data ( sometimes referred to as Anonymized Data), which refers to User Data with the following removed: personally identifiable information and the names and addresses of User and any of its Authorized Members and/or End-Customers; may be used, reproduced, sold, publicized, or otherwise exploited by Squaredance in any way, in its sole discretion.
To the extent we enter into arrangements with service providers, agents and contractors to store, handle or process personal information on our behalf, such as for data processing, document storage software support and office services, our policy will be to require such parties by contractual or other means to provide comparable privacy protection while the information is processed or handled by them.
We may display customer testimonials on our Website in addition to other endorsements. With your consent, we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at [email protected]
We will obtain a customer's consent to the collection, use and disclosure of personal information about the customer, and the consent of other individuals where required by applicable privacy legislation. We assume that an individual has consented to our reasonable collection and use of personal information consistent with the purposes for which the information was given, when the individual initiates contact with us or voluntarily provides personal information to us. We also assume that Customers who use or pay for our services consent to the reasonable collection, use and disclosure of their personal information by our professionals and agents for the conduct of the transactions or proceedings involving our Customers. Other than set out herein, we do not collect, use or disclose personal information without consent unless authorized or required by law to do so, such as in the following circumstances:
- where a court order or subpoena is issued or a regulatory or other body with jurisdiction to compel production so requires;
- when the information is publicly available within the meaning of applicable privacy legislation, such as in professional or other directories, in public registries, publicly filed court records or information appearing in published form;
- if we are required to disclose personal information to a lawful authority;
- as otherwise authorized by law.
7. Limited Collection, Use and Disclosure and Retention
We collect personal information by fair and lawful means and, wherever appropriate, directly from the individual. Wherever possible, we limit the amount of personal information we collect, use or disclose to that necessary and appropriate to provide our services and to operate our business. We limit the personal information we collect and use for customer relationships and for our promotions and to contact information and information about preferences provided by the individual.
We keep records of the work performed and services provided by us in accordance with applicable regulatory requirements and professional standards. These records may include personal information. Our records are stored with safeguards against inappropriate or unauthorized access (see Safeguards). We retain contact information about individuals for the period of time the individual subscribes to our programs, does not opt-out or continues to respond to promotions or other correspondence.
8. Accuracy of Information
In order to provide customers or subscribers with a professional level of service and to maintain appropriate contact preferences, we may ask you to update your personal information, contact information or preferences from time to time, and we provide an ongoing opt-out opportunity available by contacting the Privacy Officer. Customers are encouraged to contact the Privacy Officer to update the personal information we maintain in our customer files.
We protect personal information in our files and document management systems from loss, misuse, unauthorized access and alteration by using physically secure facilities, password protection, standard security practices and tools and well-defined internal policies and practices.
10. Access to Your Personal Information
You may request to review any personal information concerning yourself we have on file by contacting us by email at [email protected] or by mail to the following address:
Galactic Propeller Holdings Ltd. DBA Squaredance
Attn: Privacy Officer
171 East Liberty Street, Unit 310
Toronto, Ontario CANADA M6K 3P6
We will provide access to such personal information, subject to exceptions stipulated or required by applicable privacy legislation.
We will respond to complaints from individuals or questions about our compliance with this policy and with applicable privacy laws. We will investigate and attempt to resolve all complaints. To challenge our compliance with this policy please contact our Privacy Officer through the contact information listed above.
If you have any questions or concerns about your privacy and our role in protecting it, please contact our Privacy Officer through the contact information listed above.