Privacy Policy

At Corum Digital Corporation “Corum Digital” we are committed to safeguarding the privacy of our customers. This Privacy Policy applies to all of the products, services and websites offered by Corum Digital or its subsidiaries or affiliated companies; collectively, Corum Digital's “services”.

For any questions or concerns regarding this Privacy Policy or Corum Digital's treatment of personal information, please contact us using the information found in the “How To Contact Us” section below.

EFFECTIVE DATE

This policy is effective as of December 2, 2024.

DEFINITIONS

Following terms used in this privacy policy are defined as follows.

Personal Data: Any information (including opinions and intentions) which relates to an Individual Person.

Individual Person: Anyone who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data or an online identifier.

Data Controller: A natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the Processing of Personal Data.

Data Provider: The identified or Individual Person to which the Personal Data refers.

Data Protection: The process of safeguarding Personal Data from unauthorised or unlawful disclosure, access, alteration, Processing, transfer or destruction.

Third Party: An external organization with which Corum Digital conducts business and is also authorised to, under the direct authority of Corum Digital, Process the Personal Data of a Corum Digital customer, whether past, current or prospective.

Process(ed)(ing): Any operation or set of operations performed on Personal Data or on sets of Personal Data, whether or not by automated means. Operations performed may include collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Consent: Any freely given, specific, informed and unambiguous indication of the Data Provider's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the Processing of Personal Data relating to him or her.

INFORMATION WE COLLECT

In order to provide our range of services, we may collect one or more of the following types of information:

Account Information – When you sign up for a Corum Digital Account or other Corum Digital service or promotion that requires registration, you will be asked to provide your personal information (such as your name, email address and an account password). For certain services, we may also request credit card or other payment account information.

Cookies – When you visit Corum Digital or one of its associated websites, we send one or more cookies, which is a small file containing a string of characters, to your computer that uniquely identifies your browser. We use cookies to improve the quality of our service by storing user preferences and tracking user trends.

Log information – When you access Corum Digital services, our servers automatically record information that your browser sends whenever you visit a website. These server logs may include information such as your web request, Internet Protocol address, browser type, browser language, the date and time of your request and one or more cookies that may uniquely identify your browser.

Individual communications – When you send email or other communications to Corum Digital, we may retain those communications in order to process your inquiries, respond to your requests and improve our services.

Information Collected for SMS Communications
When you voluntarily provide your phone number through our website or other registration methods, we collect this information to facilitate SMS communications. This includes sending appointment reminders, service updates, troubleshooting instructions, system downtime notifications, and, with explicit consent, marketing messages.

Explicit Consent
Consent is explicitly obtained at the time you provide your phone number, such as through online forms, service agreements, or subscription confirmation texts. By opting in, you acknowledge that you understand and agree to receive SMS communications in accordance with this Privacy Policy.

We use phone numbers solely for the purposes described and in accordance with applicable laws and regulations. You can opt out of receiving SMS communications at any time by replying "STOP" to any SMS message.

DATA SOURCES

We collect Personal Data only from the Data Provider unless the nature of the business purpose necessitates collection of the Personal Data from other persons or bodies. For example, registry of a group of users for access to our systems.

HOW WE USE THE COLLECTED INFORMATION

Corum Digital only processes personal information for the purposes described in this Privacy Policy which includes maintaining general business operation and administration of Corum Digital entities, providing services to Corum Digital customers, providing ongoing administration and management of customer services and developing and improving Corum Digital products and services.

We Process Personal Data in accordance with all applicable laws and applicable contractual obligations. More specifically, we will only Process Personal Data for at least one of the following requirements:

• The Data Provider has given Consent to the Processing of their Personal Data for one or more specific purposes;
• Processing is necessary for the performance of a contract to which the Data Provider is a party to, or in order to take steps at the request of the Data Provider prior to entering into a contract;
• Processing is necessary for compliance with a legal obligation to which the Data Controller is subject;
• Processing is necessary in order to protect the vital interests of the Data Provider or of another natural person;
• Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller;
• Processing is necessary for the purposes of the legitimate interests pursued by the Data Controller or by a Third Party (except where such interests are overridden by the interests or fundamental rights and freedoms of the Data Provider, in particular where the Data Provider is a child).;

Information Collected for SMS Communications – When you voluntarily provide your phone number through our website or other registration methods, we collect this information to facilitate SMS communications. This includes delivering alerts, updates, and promotional messages in accordance with your preferences and consent.

There may be some circumstances in which Personal Data may be further processed for purposes that go beyond the original purpose for which the Personal Data was collected. In these circumstances, we will determine the fairness and transparency of any Processing beyond the original purpose by considering the relationship between the purpose for which the Personal Data was collected and the reasons for intended further Processing, as well as the context in which the Personal Data has been collected, in particular regarding the relationship between Data Provider and the Data Controller, and finally the existence of appropriate safeguards pertaining to further Processing, which may include encryption, anonymization or pseudonymization.

Corum Digital processes personal information on servers in the United States of America, Canada and in other countries. In some cases, we may process personal information on a server outside of your own country. We may do so to provide our own services and, in some cases on behalf of and according to the instructions of a third party, such as our channel “reseller” partners.

If we propose to use personal information for any purposes other than those described in this Privacy Policy, we will offer you an effective way to opt out of the use of personal information for those other purposes.

You can decline to submit personal information to any of our services, in which case Corum Digital may not be able to provide those services to you.

Standard Messaging Disclaimers for SMS Communications
For SMS communications, you will receive up to 4 messages/month based on the services you opt into. Standard message and data rates may apply as determined by your mobile carrier. These rates are your responsibility, and Corum Digital is not liable for any additional charges incurred.

We strive to ensure that SMS communications are clear, concise, and limited to the purposes you have consented to, such as appointment reminders, service updates, troubleshooting, and marketing messages where consent has been explicitly provided.

For assistance with SMS communications, reply HELP to any message or contact us at privacyofficer@corumdigital.com.

Legal Basis for Processing Personal Data
We process personal data based on one or more of the following legal bases:

• Your explicit consent, where required.
• The necessity of processing to fulfill a contract or to take steps at your request prior to entering into a contract.
• Compliance with a legal obligation.
• Legitimate interests pursued by Corum Digital, provided that such interests are not overridden by your fundamental rights and freedoms.

DATA PROTECTION

We adopt physical, technical, and organizational measures to ensure the security of Personal Data. This includes the prevention of loss or damage, unauthorized alteration, access or Processing, and other risks to which it may be exposed by virtue of human action or the physical or natural environment. Data protection measures include:

• Preventing unauthorized persons from gaining access to data processing systems in which Personal Data are Processed.
• Preventing persons entitled to use a data processing system from accessing Personal Data beyond their needs and authorizations.
• Ensuring that Personal Data in the course of electronic transmission during transport cannot be read, copied, modified or removed without authorization.
• Ensuring that access logs are in place to establish whether, and by whom, the Personal Data was entered into, modified on or removed from a data processing system.
• Ensuring that in the case where Processing is carried out by a Data Processor, the data can be Processed only in accordance with the instructions of the Data Controller.
• Ensuring that Personal Data is protected against undesired destruction or loss.
• Ensuring that Personal Data is not kept longer than necessary.

Use of Information for SMS Communications - We use your phone number solely for the purpose of sending SMS messages, including alerts, notifications, and promotional content. These messages are sent based on your explicit consent and preferences. We may also use this information to manage opt-in and opt-out preferences for SMS communications. We implement industry-standard security measures to protect personal information, including phone numbers collected for SMS communications. This includes encryption during data transmission and secure storage to prevent unauthorized access.

PERSONAL DatA from CHILDREN

Corum Digital’s range of products and services are not intended for use by children. We will not knowingly collect any personal information from minors. If you believe that we may have inadvertently collected personal information from a minor, please contact us immediately using the information in the “How To Contact Us” section below.

DATA RETENTION

We retain personal data only as long as necessary to fulfill the purposes outlined in this Privacy Policy or comply with legal, regulatory, or contractual obligations. Specific retention periods are based on:

• The duration of your relationship with us.
• Legal and regulatory requirements.
• Legitimate business needs.

Retention of SMS Communication Data
We retain phone numbers and related SMS communication data only as long as necessary to fulfill the purposes outlined in this Privacy Policy. Specifically, data used for SMS communications is retained:

• For as long as you remain subscribed to our SMS communication services.
• To comply with legal, regulatory, or operational obligations.
• For a reasonable period after opt-out to ensure compliance with user preferences and auditing requirements.

Once data is no longer needed, it is securely deleted or anonymized in accordance with our data protection standards.

INFORMATION SHARING

Corum Digital only shares personal information with other companies or individuals outside of Corum Digital in the following limited circumstances:

• We have your consent.
• Providing such information to our subsidiaries, affiliated companies or other trusted businesses or persons for the purpose of processing personal information on our behalf. We require that these parties agree to process such information based on our instructions and in compliance with this Privacy Policy and any other appropriate confidentiality and security measures.
• We have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process or enforceable governmental request, (b) enforce applicable Terms of Service, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address fraud, security or technical issues, or (d) protect against imminent harm to the rights, property or safety of Corum Digital, its users or the public as required or permitted by law.
• Opting Into and Out of SMS Communications - By providing your phone number during registration or through other forms, you consent to receive SMS messages from us. You will receive up to 4 messages per month, depending on the services you subscribe to. If you no longer wish to receive these messages, you can opt out at any time by replying “STOP” to any SMS message you receive from us. Alternatively, you can contact us at privacyofficer@corumdigital.com to request removal.

As part of the opt-in process, users are provided with a link to this Privacy Policy to ensure they have access to all relevant information about how their data will be used before subscribing to SMS communications.

• Managing SMS Preferences -In addition to replying “STOP” to an SMS message, you may also update your preferences by contacting us directly at [phone number] or through our [support link]. Our support team will ensure your preferences are updated promptly.

If Corum Digital becomes involved in a merger, acquisition, or any form of sale of some or all of its assets, we will provide notice before personal information is transferred if it becomes subject to a different privacy policy.

We may share with third parties certain pieces of aggregated, non-personal information. Such information does not identify you individually.

Aggregated and Anonymized Data - We may share aggregated or anonymized data, such as statistical data about website usage or service performance, with third parties. This data does not contain information that identifies you as an individual and is used for purposes such as improving our services, conducting research, or analyzing trends.

International Data Transfers - Personal data collected may be transferred to, and stored and processed in, countries other than your own. These countries may have data protection laws that differ from those in your jurisdiction. When we transfer personal data across borders, we take steps to ensure it is treated securely and in accordance with this Privacy Policy and applicable laws.

Please contact us using the information in the “How To Contact Us” section below for any additional questions about the management or use of personal data.

Obtaining InforMation about your personal data

You are entitled to obtain, based upon a request made in writing and upon successful verification of your identity, the following information about your Personal Data:

• The purposes of the collection, Processing, use and storage of your Personal Data.
• The source(s) of the Personal Data, if it was not obtained from the Data Provider;
• The anticipated period of storage for the Personal Data.

Data Providers shall also have the right to require Corum Digital to correct or supplement erroneous, misleading, outdated, or incomplete Personal Data.

To request access to your data or request a correction, please submit your request in writing using the information found in the “How To Contact Us” section below.

Your Rights Related to SMS Communications - You have the right to:

• Request access to the data we have collected for SMS communications.
• Request correction or deletion of your phone number from our SMS databases.
• Revoke your consent to receive SMS messages at any time. To do so, reply “STOP” to any SMS message you receive from us or contact us directly at privacyofficer@corumdigital.com.

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LAW ENFORCEMENT REQUESTS AND DISCLOSURES

If requested by law enforcement agencies or judicial courts, Personal Data may be shared without the knowledge or Consent of a Data Provider. This is the case where the disclosure of the Personal Data is necessary for the prevention or detection of crime, the apprehension or prosecution of offenders, the assessment or collection of a tax or duty, or by the order of a court or by any rule of law

If we Process Personal Data for one of these purposes, then it may apply an exception to the Processing rules outlined in this policy but only to the extent that not doing so would be likely to prejudice the case in question.

CHANGES TO THIS PRIVACY POLICY

Please note that this Privacy Policy may change from time to time and as such, we will post any Privacy Policy changes on this page and, if the changes are significant, we will provide a more prominent notice. Each version of this Privacy Policy will be identified at the top of the page by its effective date.

For significant changes to this Privacy Policy, we will notify users through email, SMS, or a prominent notice on our website before the changes take effect. Your continued use of our services indicates your acceptance of any changes.

HOW TO CONTACT US

Accessibility - We are committed to making our privacy policy accessible to all individuals. If you require this Privacy Policy in an alternative format, please contact us using the details in the “How To Contact Us” section below.

For any questions or concerns regarding this Privacy Policy or Corum Digital's treatment of personal information, please contact us at privacyofficer@corumdigital.com or write to us at: 2501 Rutherford Road, Unit #33, Concord, Ontario. L4K 2N6 Canada Attn: Privacy Officer.