- If you opt in to our newsletter(s), we’ll send you emails and other stuff that may be of interest to you. You can unsubscribe from our marketing emails at any time.
- We collect Personal Data, Site Data, Application Data, and Anonymous Data (as defined below) to make our website(s), services, and applications more useful to you.
- If we do collect Personal Data (as defined below), we will only use this information for lawful purposes and will store and retain this information for as long as required by applicable law.
- You can contact us at any time to update or remove any Personal Data that we have collected and stored about you.
Lawful Basis for Processing Data
In certain jurisdictions, the processing of your Personal Data (as defined below) is lawful only if it is permitted under data protection legislation. In this case, we have a lawful basis for each of our processing activities (unless an exemption applies) as outlined below:
- Legitimate Interest. We will process your Personal Data based on Legitimate Interest, and particularly where it is used for marketing and business purposes, and to contact you to start a conversation regarding your use of the Site or any Assembly newsletters that you wish to join.
- Legal Obligation. We may also process your Personal Data based on other lawful basis such as where the processing is necessary to comply with applicable law.
- Contract. We may process your Personal Data where such processing is required in order to fulfill an agreement or contract with you.
How We Collect and Use Personal and Anonymous Data
When you access the Site, register for or use any associated products and/or services, install any software applications, or opt-in to receive newsletters and other communications from us, we may collect Personal Data and Anonymous Data from you. We may also collect Personal Data and Anonymous Data when you send us information or communications.
“Personal Data” means data that allows someone to identify or contact you, including, for example, and without limitation:
- your name
- phone number
- physical address
- Internet Protocol (IP) address geographic location or geolocation account name
- email address
- credit card information
Personal Data may be used for the purposes of recording the transaction when you access the Site or when you use any of the Software or any associated products and/or services. Assembly does not knowingly collect any sensitive personal data or any data defined under special categories of the applicable law(s).
“Anonymous Data” refers to data about you that is not associated with or linked to your Personal Data. Anonymous Data does not permit the identification of individual persons.
We may use Personal Data collected from you for the following general purposes:
- to fulfill your requests to receive information from us;
- to fulfill your requests for our Software and any associated service(s);
- to improve the Site, the Software, and any associated products and/or service(s);
- to contact you to resolve problems that you may encounter with the Site, the Software, and any associated service(s);
- to send you information about the Software and any associated service(s) including confirmations, technical notices, updates, security alerts, and support and administrative messages;
- to communicate with you about products and services offered by us and our selected partners;
- to engage with third-party service providers so that you can access and use the Software, the Site, and any associated service(s); and
- to periodically conduct market research regarding your use of the Site and our services.
If and when we use a third-party payment processing provider/merchant, third-party technical support provider, third-party technology provider, or third-party hosting provider, we ensure that the same privacy criteria, as defined herein, are in place with such third parties. We do not knowingly collect personal information from persons under the age of eighteen (18).
How We Collect and Use Site Data
“Site Data” refers to data about how you use the Site. We may collect certain information from you including, but not limited to: User IP addresses, OS version, OS localization, device type, etc. We obtain this information from third-party traffic monitoring service providers. Other than User IP address, the Site does not, and will not, collect any other Personal Data from you without your prior approval. The Site Data we collect is primarily used to report Site usage and statistics,
to improve the Site, and to track the performance of various marketing initiatives. Site Data may also be used by Assembly to answer questions that customers have about their use of the Site.
How We Collect and Use Application Data
Sharing of Personal Data
We will never sell, trade, or rent any Personal Data, Site Data, or any Anonymous Data that may contain Personal Data, to any third party.
In certain special cases, we may use, retain, or disclose your Personal Data when we have reason to believe that using, retaining, or disclosing such information is necessary to identify, contact, or bring legal action against someone who may be causing injury to you, or is otherwise injuring or interfering with Assembly’s rights, property or operations, other users of the Site and/or Software, or anyone who could be harmed by such activities. We may also disclose your Personal Data when we believe the law requires it, or in response to any demand by law enforcement authorities in connection with a criminal investigation, or civil or administrative authorities in connection with a pending civil case or administrative investigation.
If we determine, in our sole discretion, that you have engaged in conduct which might be considered unlawful, fraudulent, or which might harm or damage the reputation or standing of Assembly with either the general public or with a business partner or potential business partner of Assembly, we reserve the right to release your Personal Data to such persons or third parties, as we consider necessary, in order to prevent you from causing injury to, or otherwise injuring or interfering, now or in the future, with Assembly’s rights, property or operations or otherwise the rights, property or operations of anyone which could be harmed by such conduct.
Your Rights with Respect to Your Personal Data
This section applies if you are located in the European Union (EU) or European Economic Area (EEA). In accordance with applicable privacy law, you have the following rights in respect of your personal information that we hold:
- Right of access and portability. The right to obtain access to and to receive your Personal Data.
- Right to rectification. The right to obtain rectification of your Personal Data without undue delay where that personal information is inaccurate or incomplete.
- Right to erasure. The right to obtain the erasure of your Personal Data without undue delay in certain circumstances, such as where the Personal Data is no longer necessary in relation to the purposes for which it was collected or processed.
- Right to restriction. The right to obtain the restriction of the processing undertaken by us on your Personal Data in certain circumstances, such as where the accuracy of the Personal Data is contested by you, for a period enabling us to verify the accuracy of that Personal Data.
- Right to object. The right to object, on grounds relating to your particular situation, to the processing of your Personal Data, and to object to processing of your Personal Data for direct marketing purposes, to the extent it is related to such direct marketing.
California Consumer Protection Act
Without being discriminated against for exercising these rights, California law gives its residents the right to request that we disclose what personal information we collect from you, to delete that information, and to opt-out of the sale of your personal information (if we sell such information), subject to certain restrictions. For security purposes, we will verify your identity – in part by requesting certain information from you — when you request to exercise your California privacy rights. You also have the right to designate an agent to exercise these rights on your behalf. This section describes how to exercise those rights and our process for handling those requests.
Right to Know
If you are a California resident, you may submit, free of charge, but no more than twice in a 12- month period, a verifiable request for the following information:
- The specific pieces of personal information we have about you;
- The categories of personal information we collected, sold, or disclosed for a business purpose about you within the last 12 months;
- The categories of sources from which the personal information was collected;
- The purposes for which the information was collected or sold; and
- The categories of third parties to whom the information was sold, disclosed for a business purpose, or otherwise shared.
If possible, we will provide this information to you in a readily usable format that allows transmission to another entity. The easiest way to submit a request and receive your report is to email us at [email protected].
Right to Delete
If you are a California resident, you may submit a verifiable request for us to delete the personal information we have collected about you. The easiest way to submit a request for deletion is to email us at [email protected].
Right to Opt-Out
California residents may opt out of the “sale” of their personal information, as defined by the CCPA. The right to opt-out DOES NOT APPLY when:
- You direct us to disclose your personal information or use us to interact with a third party and the third party does not sell the personal information;
- We use or share an identifier solely to alert a third party you have opted out of the sale of your personal information;
- Your personal information is transferred as an asset as part of a transaction in which the third party assumes control of all or part of our business, in which case the third party would have to tell you in writing if it materially changes how the information is used or shared; and
- We use or share your personal information under a written contract with a service provider necessary to perform a business purpose. Here, the service the service provider performs is on our behalf, and our written contract prohibits it from keeping, using or disclosing your personal information for any purpose other than for the specific purpose identified in the contract.
However, we have provided you with a system to record your preference that your data not be sold in the future. You may make this request emailing us at [email protected].
Right to be Free from Discrimination
We may not discriminate against you because you have exercised your rights, including, for example, by denying you access to our owned and/or operated websites.
If you would like to designate an authorized agent to make a request on your behalf, please be sure the agent can (i) demonstrate you have provided written permission for the agent to submit the request on your behalf, and (ii) provide proof of his or her own identity. If the agent does not satisfy these requirements, we will deny the request.
Cookies and Similar Technologies
Do Not Track
If you opt-out of having your information collected through cookies and other web technologies, your existing display advertising cookie(s) will be deleted and a new cookie will attempt to be placed that instructs third-party service providers not to track your future activities when that cookie is detected (a “do-not-track” cookie). If your browsers are configured to reject cookies when you visit our opt-out page, a “do-not-track” cookie cannot be set on your computer. Also, if you subsequently erase “do-not-track” cookies, use a different computer or change web browsers, you will need to opt-out again. We currently do not respond to browser “do-not-track” signals.
Third-party Links. The Site may contain links to other third-party owned and/or operated websites and, where you request information from third-party providers, we may transfer you directly to the websites of such third-party providers. Assembly is not responsible for the privacy practices or the content of such third-party websites. In some cases, you may be required to provide certain information to register or complete a transaction at such website. These third- party websites have separate privacy and data collection practices and Assembly has no responsibility or liability relating to them. We do not endorse, nor are we responsible for the accuracy of, the privacy policies and/or terms and conditions of such third-party website. These third-party entities are independent third parties and are not affiliated with Assembly.
Third-Party Offers – Assembly may provide its users with the opportunity to receive special offers, products and/or services from third parties. Where you indicate the desire to receive certain offers, products or services from a third party during the applicable information collection process, your Personal Data that was provided during that information collection process will be shared with the applicable third party so that such third party may provide their products and/or services to you so that you do not have to complete another information collection form to purchase or receive that product or service.
Third-Party Cookies – Clicking on any third-party offers may add and place cookies on your computer prior to directing you to the applicable advertiser’s site. These third parties have separate cookie polices and Assembly has no responsibility or liability relating to them. If you do not wish to receive cookies, you may set your browser to reject cookies or to alert you when a cookie is placed on your computer. You are not required to accept cookies, however, if your browser rejects our cookies you may not be able to use all of the Site and/or Software functionality.
Third-party Technology/Software/Service/Solutions Providers
The Site and Software may contain certain software technologies and services licensed from third-party providers. Assembly may engage with certain third-party services and solutions providers such as data hosting service providers, traffic monitoring service providers, advertising service providers, payment processing service providers, and email marketing service providers. These third-party providers have separate privacy and data collection practices and policies, and Assembly has no responsibility or liability relating to them. We do not endorse, nor are we responsible for the accuracy of the terms and conditions of any third-party privacy policies. These third-party entities are independent third parties and are not affiliated with Assembly.
Assembly may be using or sharing your Personal Data for Legitimate Interest purposes with third-party service providers, including without limitation:
- New Relic (Traffic Monitoring/Optimization Services); https://newrelic.com/privacy
- CloudFlare (Traffic Monitoring/Optimization Services); https://www.cloudflare.com/security-policy/
- Pingdom (Website Performance Monitoring/Optimization Services); https:// www.solarwinds.com/legal/privacy
- Google Analytics (Traffic/Campaign Monitoring Services); https://policies.google.com/ privacy
- Google Tag Manager (Traffic/Campaign Monitoring Services); https:// policies.google.com/privacy
- Google Maps (Geolocation Services); https://policies.google.com/privacy
- Google AdSense (Advertising Services); https://policies.google.com/privacy
- Google Adwords Remarketing (Advertising Services); https://policies.google.com/privacy
- Digital Ocean (Website Hosting and Infrastructure Services); https://www.digitalocean.com/legal/privacy/
- Google Website Optimizer (Traffic Monitoring/Optimization Services); https://policies.google.com/privacy
- Facebook Remarketing (Remarketing and Behavioral Targeting); https://www.facebook.com/about/privacy/update
- Facebook Custom Audience (Remarketing and Behavioral Targeting); https://www.facebook.com/about/privacy/update
- Amazon Web Services; https://aws.amazon.com/privacy/
- Campaign Monitor; https://www.campaignmonitor.com/policies/
- Mixpanel; https://mixpanel.com/legal/privacy-policy/
Security of Data
Data Retention Period
Any Personal Data that is collected and stored by Assembly will be retained only for as long as required in order to provide certain products and/or services to you, or as required by applicable law. Any Personal Data that is no longer required by Assembly will be destroyed.
Assembly Technologies Inc.
#520-1515 Douglas Street
Victoria BC V8W 2G4
We reserve the right to limit or deny your request to view, update, or remove your Personal Data if you have failed to provide us with sufficient information to verify your identity.