Introduction and Scope
This document is provided as a template to assist the privacy officer and legal counsel in generating a privacy notice to users and data subjects about the use and processing of their personal data. It is recommended that a thorough review of all privacy and other legal requirements are considered when drafting the formal privacy notice and publishing it for data subjects to review before the collection of their personal information.Data Controller and Data Processor
Lansare Corporation’s business customers are the data controllers for most of the information that is entered into custom web applications hosted by Lansare Corporation. Lansare employees may access this data periodically in order to deliver support or services. This positions Lansare Corporation as the data processor for most information stored and processed by Lansare Corporation. There are some pieces of information that are collected directly by Lansare Corporation to facilitate security, logging, and application performance. These items include IP address and behavior within Lansare’s virtual data center environment. For these pieces of information, Lansare Corporation acts as the data controller and processor. Additionally, Lansare Corporation employs a variety of technologies and partners that periodically act as sub-processors (detailed list below). If users have any questions or concerns about the processing and handling of their personal information, they may reach out to Lansare Corporation directly by email at businessadmin@lansare.com.Types of Data Collected
The Lansare Corporation customer web applications and supporting applications collect the following types of personal data: cookies, usage data (e.g., page and link clicks), the user’s IP Address and login information, company, and email address. All data that is collected is at the direction of Lansare customers within the scope of their specific applications. Complete details on each type of personal data collected are provided in the dedicated sections of this Privacy Policy or by specific explanation texts displayed before the data collection. The Lansare Corporation corporate website does not collect personal data of any kind. Specific data may be required for Lansare to provide services on behalf of a customer, on a customer’s web application hosted by Lansare Corporation . Whether or not mandatory data is noted within the application is at the direction of each specific customer. Users who are uncertain about which personal data is mandatory should first contact their application support team, who are responsible for managing employee access and data collection. Users may contact Lansare Corporation at businessadmin@lansare.com. Any use of cookies–or other tracking tools–by the Lansare Corporation website, or each customer’s specific web application serves the purpose of providing the service for which Lansare Corporation has been engaged, in addition to any other purposes described in the present document.Mode, Place, and Methods of Processing the Data
Lansare Corporation takes appropriate security measures to prevent unauthorized access, disclosure, modification, or data destruction. Data is processed using computers or tech-enabled tools, following organizational policies and procedures strictly related to the purposes indicated. In some cases, data may be accessible to Lansare Corporation employees involved with the Lansare Corporation website’s operation, the Lansare Corporation web application (platform), and supporting applications. Data may also be accessible to external parties appointed, if necessary, as data processors or sub-processors by Lansare Corporation. External parties may include third-party technical service providers, hosting providers, and IT companies.Legal Basis of Processing
Lansare Corporation may process personal data relating to users if one of the following applies:- Users have given their consent for one or more specific purposes.
- Provision of data is necessary for the performance of an agreement with the user.
- Processing is necessary for compliance with a legal obligation.
- Processing is necessary for the legitimate interests pursued by the controller or by a third party.
Place
The data is processed at Lansare Corporation’s operating offices, hosting facilities, and, for some data, third-party sub-processors. The majority of data is stored and processed within Canada. In some cases data may be stored within the US or EU via third-party sub-processors. Depending on the user’s location, data transfers may involve transferring the user’s data to a country other than their own. To find out more about the processing of such transferred data, users can consult the section containing details about the processing of personal data. Users are entitled to learn about cross-border data transfers. If any such transfer occurs, users can find out more by checking the relevant sections of this document or inquiring directly with Lansare Corporation.Retention Time
Personal data is processed and stored for as long as required to fulfill the purpose for which it is collected. Therefore:- Personal data collected for the performance of a contract between Lansare Corporation and a business customer is retained until such contract has been entirely performed or the business customer asks for the data to be deleted.
- Personal data collected for Lansare Corporation’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding Lansare Corporation’s legitimate interests within the relevant sections of this document or by contacting Lansare Corporation.
The Purposes of Processing
The data concerning the user is collected to allow Lansare Corporation to provide its services, as well as for the following purposes: analytics, user database management, managing contacts and sending messages, handling payments, interaction with external social networks and platforms, remarketing and behavioral targeting, contacting the user, displaying content from external platforms, hosting and backend infrastructure, interaction with live chat platforms, and spam protection. Users can find further detailed information about such purposes of processing and the specific personal data used for each purpose in the respective sections of this document.Detailed Information on the Processing of Personal Data
Personal data is collected for the following purposes and using the following services and third parties:Analytics
The services contained in this section enable Lansare Corporation to monitor and analyze web traffic and can be used to keep track of user behavior.Google Analytics (Google Inc.)
Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the data collected to track and examine the use of this application, to prepare reports on its activities, and to share the reports with other Google services. Google Analytics is used only within a customer’s implementation. Scope and usage is designated by each specific customer. Google may use the data collected to contextualize and personalize the ads of its own advertising network. Personal data collected: cookies and usage data. Place of processing: US – Privacy Policy.Contacting the User
Mailing List or Newsletter (The Lansare Corporation Web Application)
By registering on the mailing list or for the newsletter, the user’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning the Lansare Corporation web application. The user’s email address may also be added to this list due to signing up via the Lansare Corporation website or the Lansare Corporation web application, or after making a purchase. Personal data collected: address, city, company name, cookies, country, email address, first name, last name, phone number, job role, province, state, usage data, and ZIP/Postal code.Phone Contact (The Lansare Corporation Web Application)
Users that provide their phone number might be contacted for commercial or promotional purposes related to the Lansare Corporation web application or for fulfilling support requests. Personal Data collected: phone number.Contact Form (The Lansare Corporation Web Application)
By filling in the contact form with their data, users authorize the Lansare Corporation web application to use these details to reply to requests for information, quotes, or any other kind of request as indicated by the form’s header. Personal data collected: address, city, company name, country, email address, first name, last name, phone number, job role, province, state, and ZIP/Postal code.Displaying Content from External Platforms
This type of service allows users to view content hosted on external platforms directly from the pages of the Lansare Corporation web application and interact with them. This type of service might still collect web traffic data for the pages where the service is installed, even when users do not use it.Google Fonts (Google Inc.)
Google Fonts is a typeface visualization service provided by Google Inc. that allows this Application to incorporate content of this kind on its pages. Personal data collected: usage data and various types of data as specified in the service’s privacy policy. Place of processing: US – Privacy Policy. Privacy Shield participant.Hosting and Back-End Infrastructure
This type of service has the purpose of hosting data and files that enable the Lansare Corporation website and the Lansare Corporation web application to run and be distributed. Additionally, these services provide the infrastructure to run specific features or parts of the application. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the personal data is stored.Microsoft Azure (Microsoft, Inc.)
Microsoft Azure is a hosting and backend service provided by Microsoft, Inc. Personal data collected: various types of data as specified in the privacy policy. Place of processing: See the Microsoft Legal Information – Legal Information.Managing Contacts and Sending Messages
This type of service makes it possible to manage a database of email contacts, phone contacts, or any other contact information to communicate with the user. These services may also collect data concerning the date and time when the message was viewed by the user and when the user interacted with it, such as by clicking on links included in the message. These services are only used by Lansare Corporation in conjunction with client implementationsTwilio SendGrid (SendGrid, Inc.)
SendGrid is an email proxy service used to send email messages on behalf of clients of Lansare Corporation. Personal data collected: email address and usage data. Place of processing: US – Privacy Policy.Spam Protection
This type of service analyzes the traffic of the Lansare Corporation website and the Lansare Corporation application, potentially containing users’ personal data, with the purpose of filtering it from parts of traffic, messages, and content that are recognized as spam.Further Information about Personal Data
The Rights of Users
Users may exercise certain rights regarding their data processed by Lansare Corporation within the context of it’s client implementations. Requests need to be initiated with the customer. In particular, users have the right to do the following:-
Withdraw their consent at any time.
Users have the right to withdraw consent after they have previously given their consent to the processing of their personal data.
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Object to processing of their data.
Users have the right to object to the processing of their data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
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Access their data.
Users have the right to learn if Lansare Corporation is processing their data, obtain disclosure regarding certain aspects of the processing, and obtain a copy of the data undergoing processing.
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Verify and seek rectification.
Users have the right to verify their data accuracy and ask for it to be updated or corrected.
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Restrict the processing of their data.
Users have the right, under certain circumstances, to restrict the processing of their data. In this case, Lansare Corporation will not process their data for any purpose other than storing it.
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Have their personal data deleted or otherwise removed.
Users have the right, under certain circumstances, to obtain the erasure of their data from Lansare Corporation.
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Receive their data and have it transferred to another controller.
Users have the right to receive their data in a structured, commonly used, machine-readable format, and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the data is processed by automated means and that the processing is based on the user’s consent, on a contract that the user is part of, or on precontractual obligations.
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Lodge a complaint.
Users have the right to bring a claim before their competent data protection authority.
Details About the Right to Object to Processing
Where personal data is processed for the public interest, in the exercise of an official authority vested in Lansare Corporation or for the legitimate interests pursued by Lansare Corporation, users may object to such processing by providing a ground related to their particular situation to justify the objection. However, users must know that should their personal data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn whether the Lansare Corporation is processing Personal Data for direct marketing purposes, users may refer to the relevant sections of this document.How to Exercise These Rights
Any requests to exercise user rights can be directed to Lansare Corporation through the contact details provided in this document (businessadmin@lansare.com). These requests can be exercised free of charge and will be addressed by Lansare Corporation as early as possible and always within one month.Cookie Policy
The Lansare Corporation website and Lansare Corporation web application use cookies. To learn more and for a detailed cookie notice, the user may consult the Cookie Policy.Additional Information about Data Collection and Processing
Legal Action
Users’ personal data may be used for legal purposes by Lansare Corporation in court or the stages leading to possible legal action arising from improper use of this application or the related services. The users declare they are aware that Lansare Corporation may be required to reveal personal data upon request of public authorities.Additional Information About Users’ Personal Data
In addition to the information contained in this privacy notice, this application may provide users with additional and contextual information concerning particular services or the collection and processing of personal data upon request.System Logs and Maintenance
For operation and maintenance purposes, this application and any third-party services may collect files that record interaction with this application (e.g., system logs) using other personal data (e.g., IP Address) for this purpose.Information Not Contained in This Notice
More details concerning the collection or processing of personal data may be requested from Lansare Corporation at any time. Users may use the contact information at the beginning of this document.How “Do Not Track” Requests are Handled
This application does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honor “Do Not Track” requests, users should read their privacy policies.Changes to This Privacy Notice
Lansare Corporation reserves the right to make changes to this privacy notice at any time by giving notice to users on this page and possibly within this application or–as far as technically and legally feasible–sending a notice to users via any contact information available to Lansare Corporation. Users are strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. Should the changes affect processing activities performed based on the users’ consent, Lansare Corporation shall collect new consent from the user where required.Definitions and Legal References
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information—including a personal identification number—allows for the identification or identifiability of a natural person.Usage Data
Information collected automatically through this application (or obtained by services employed in this application)can include: the IP addresses or domain names of the computers utilized, the Uniform Resource Identifier (URI) addresses, the time of the request, the method used to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the users’ browser and operating system, the various time details per visit (e.g., the time spent on each page within the application), and the information on the path followed within the application with particular reference to the sequence of pages visited, and other parameters about the device operating system or the users’ IT environment.User
The individual using this application who, unless otherwise specified, coincides with the data subject.Data Subject
The natural person to whom the personal data refers.Data Processor
The natural or legal person, public authority, agency, or other body that processes personal data on behalf of the controller, as described in this privacy notice.Sub-Processor
This refers to any additional third party who processes personal data on behalf of the data processor in fulfilling contractual obligations and services.Data Controller
The person, public authority, agency, or other body that determines the purposes and means of processing personal data, including the security measures concerning the operation and use of this application.