- We will not collect your Personal Information without your knowledge;
- We will take reasonable measures to protect the security of your Personal Information; and
“Advisor” means an individual who has been trained in the ORI Proprietary Methodology or is otherwise qualified to review Surveys using the ORI Proprietary Methodology, and who administers Surveys to Survey Takers, analyzes the scores and Reports generated by ORI from these Surveys, and interprets these scores, Surveys and Reports using the ORI Proprietary Methodology.
“Customer” means an individual, business, organization or other entity which purchases services relating to ORI’s Products or Services (defined below) from an Advisor or directly from ORI (as the context requires).
“ORI Proprietary Methodology” means and includes, without limitation, ORI’s proprietary scoring methods and algorithms, the Interactive Webcube®, survey statement and question sets, drivers and competency sets, survey analysis techniques/visualizations and the research and training used by ORI in connection with the Products or Services described herein and on the Site.
“Personal Information” means any information, recorded in any form, about an identified individual, or an individual whose identity may be inferred from the information. This includes, for example, name, email address, mailing address, telephone number, billing information, account information, and other information incidental to providing or receiving Products or Services. It also includes other information, such as IP address, device information, or other Session Data that can reasonably be linked to a specific individual, computer or other device.
“Products or Services” means the products or services promoted, sold, or available for sale from the Site or through ORI personnel.
“Report” means an analysis of the scoring and responses provided in connection with a Survey, that is developed using the ORI Proprietary Methodology, and which (i) an Advisor, using the ORI Proprietary Methodology, may interpret during one or several feedback sessions or interpretation sessions with Customer; or (ii) a Customer may use in its business according to its needs.
“Site” means www.optimizer720.com.
“Survey” means an instrument, questionnaire, or series of tests that are completed by a Survey Taker in view of the preparation of a Report or to provide information about, or to, a Survey Taker, Customer, or Advisor.
“Survey Taker” means an individual who takes, will take, or has taken a Survey.
If you reside in a country or territory that restricts the transfer of Personal Information out of that country or territory, you agree to the transfer, storage, and processing of your Personal Information to countries, including Canada, that may not have data protection laws that provide the same level of protection as those that exist in your country of residence.
Children under 13 are not permitted to use the Site without their parent’s or guardian’s consent. Should a child whom we know to be under 13 send Personal Information directly to us, we will use that information only to respond directly to that child to inform him/her that we must have parental consent before receiving his/her information.
LINKS TO EXTERNAL SITES
WHAT PERSONAL INFORMATION WE COLLECT AND HOW
We collect only such Personal Information as necessary to provide our Products or Services to you, inform you about our Products and Services, continue our research in the field, and improve our Site, Products, Services, and your experience interacting with ORI. In some cases, we ask questions to which the response is optional, and these questions are identified as such. You are free not to respond to these optional questions. We describe below the different ways in which we collect or obtain Personal Information.
If you register or create an account, we require that you fill out a form to register as a Customer. We collect your name, contact information, and other information, and may ask you for other optional information that helps us serve you better.
If a potential Advisor creates an account, we collect additional information about the person’s practice and credentials, as necessary to assess the qualifications of the applicant to complete the purchase and/or become an Advisor.
If you purchase a Product or Service, we collect your contact information as necessary to fulfill the order (such as name, address, shipping information, email address, or telephone number) and optional information if you provide it.
If you purchase a Product or Service for delivery to, or use by, another person, we collect your Personal Information as the person initiating the purchase, and Personal Information about that other person (such as name, shipping address, telephone number or email address) as necessary to fulfill the order. By providing another person’s Personal Information, you represent that you have that person’s permission to do so.
When you make a purchase online, we may collect payment information ourselves or direct you to our payment processor’s website, which directly collects your payment information. If a payment processor is used, ORI only receives a notice of the receipt of the payment, a confirmation number (for verification purposes), the name and contact information of the recipient of the Product or Service, and the name and contact information of the cardholder if different from the name of the person receiving the Product or Service.
If a Survey Taker completes a Survey (e.g., an associate, manager, etc.), we collect the Survey Taker’s unique identifier and in some cases, the Survey Taker’s type of business. We collect the responses provided to the questions in the Survey. In this case, we do not know the identity of the Survey Taker. We only know the identity of the Advisor, and the unique identifier that has been assigned to each Survey Taker. Survey Takers have the choice to “self-identify”, meaning the Survey Taker’s name will be associated with his or her responses. Self-identification is optional and Survey Takers who exercise this option acknowledge and agree that their responses will be shared with the Advisor and/or Customer. Survey Takers who are concerned about their Personal Information in this regard are encouraged to not self-identify.
If a Survey Taker completes a Survey on his or her own initiative (i.e. by participating in a marketing presentation or demonstration), using our online service, we collect the Survey Taker’s contact information, and in some cases, the type of business or industry of the Survey Taker or the number of employees working at the Survey Takers’ workplace. We collect the response provided to the statements and questions in the Survey. In this case, we know the identity of the Survey Taker and that of the person who paid for the Survey, if applicable. The Survey Taker authorizes us to store the Personal Information provided and to use it in order to produce the Report.
If you choose to participate in one of our surveys, we may collect Personal Information such as your name, email address (to avoid duplicate responses), as well as any other Personal Information that you may provide in your survey responses. The responses from Survey Takers are compiled in an anonymized (e.g., non-personally identifiable) format.
If you are a Customer or other business contact, or if you are an employee or agent of a Customer or business contact, we may collect your email address, telephone, contact information, and correspondence in the regular course of our interaction with you.
We may collect Personal Information that you provide in your correspondence and communications with us.
We may receive Personal Information about you from third parties, such as from Customers, Advisors, Advisors’ employers, websites where we advertise, business partners, and service providers. Some of this information pertains to a specific individual; other information can only be linked to an access point or a device.
If you become Certified in one or more of our Products or Services, we collect information regarding the details of your certification, such as your name, the instrument in which you are certified, the date of your certification, and the current status of your certification. If you become Certified, you may register to create a profile, which displays your credentials and other information about you, which will be accessible to visitors of the Site.
We collect only the Personal Information that we need for the purposes of providing services to our Customers. We normally collect your Personal Information directly from you. We may collect your information from other persons with your consent or as authorized by law. If you wish to reduce the amount of Personal Information collected about you when completing a Survey, you should choose the option to not ‘self-identify’ while completing the Survey.
HOW WE USE PERSONAL INFORMATION
We use Personal Information in order to provide and enhance the Products or Services that we offer as explained below:
In connection with Surveys -- We use the responses to a Survey to score the Survey and prepare the related Report. The Report is delivered to our Customer. We retain a copy of your responses and the related Report in accordance with our record retention policy. All personal information is anonymised to protect your Personal Information, unless you self-identify.
For maintenance purposes -- We may use IP addresses and session data to diagnose problems with our server, and to administer our Site.
For marketing purposes -- We may use Customer email addresses or other contact information to send mailings, newsletters, and other marketing collateral regarding product information and releases. We may use your telephone number to contact you for marketing purposes.
For Survey analysis -- The information that we collect through our Surveys is not used other than to garner Survey results and statistical analysis. Such data are used in aggregate form only and never disclose an individual's identity or Personal Information. Authorized ORI personnel also have access to anonymized (e.g., non-personally identifiable) Survey scores for long term statistical analysis. This information is solely for the Advisor or ORI's use in evaluating the findings.
TO WHOM WE DISCLOSE PERSONAL INFORMATION
From time to time, we may disclose Personal Information to someone other than the individual who provided this information, as follows:
Surveys Reports & Data Visualization Tools – ORI provides its Advisors with the information that they need to properly counsel or advise their clients, customers, and employees, as applicable. If you are taking a Survey at the direction of one of our Advisors, that Advisor will receive from ORI a Report on the Survey that you took, and a set of tools to visually display the Survey’s aggregated data, so that he or she may properly counsel or advise Customer or provide Customer with other services.
The Public – If you are or become Certified as an Advisor for our Products and Services, we may share information regarding your certification, such as your name, the instruments in which you are certified, the date of your certification, its scope, and the current status of your certification with the public, and you hereby authorize us to do so.
Foreign Advisors – ORI may provide advisors in foreign markets with a list of Customers (including name and contact information) or prospective Customers residing in that advisor’s ORI-approved area of distribution. ORI will do so only when it reasonably believes that providing such information will permit the Advisor to improve the service to ORI Customers or prospective Customers in that advisor’s area, and only when the advisor’s use of such information is in accordance with ORI’s privacy policies in general.
Service providers – We may engage certain third parties to perform functions and provide services to us, including, without limitation, customer relationship management, contract management, shipment, order fulfillment, payment/credit card processing, mass mailing, hosting and maintenance, database storage and management, business analytics, fraud prevention, and direct marketing campaign service providers.
Pursuant to written agreements between ORI and these service providers, each of these service providers only has access to such Personal Information as necessary to fulfill its obligation to ORI, is not permitted to use Personal Information for any purposes other than those directed by ORI, and is required to act in a manner consistent with the relevant principles articulated in this Policy.
Law Enforcement; Litigation – Certain federal, provincial, local, or other government regulations may require that we disclose information that we hold. In such cases, we will use reasonable efforts to disclose only the Personal Information required under applicable law, such as in response to a facially valid court order, warrant or subpoena issued or made by a court, person or body. We may use or disclose Personal Information (a) if we believe in good faith that a law, regulation, rule or guideline requires it; or (b) to a person who needs the information because of an emergency that threatens the life, health or security of an identified group or person.
Aggregated data – Other than when Survey Takers self identify, if ORI provides a third-party with Personal Information, it will be in the form of aggregated data and used for product development, research, or statistical analysis. Aggregated data are created from records that are stripped of all personal identifiers, such as a combination of thousands of answers to survey questions and instrument responses.
HOW WE RETAIN PERSONAL INFORMATION
HOW WE PROTECT PERSONAL INFORMATION
We follow generally accepted industry standards to protect Personal Information, during transmission and once we receive it. We use administrative, physical, and technical measures designed to protect it from any unauthorized access, loss, misuse, disclosure, alteration, or destruction.
When we need to transfer information out of our firewall, we use industry-standard technological means to protect Personal Information while in transit through the Internet. We use encryption and a comprehensive authentication protocol to provide reasonable security.
No method of transmission over the Internet, or method of electronic storage, is fully secure, however. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.
We exercise reasonable efforts to keep your Personal Information accurate. However, we need your help in making sure that your Personal Information is correct in our systems. Please notify us of changes to information that you have previously provided by contacting the Chief Privacy Officer at the address set out below.
We protect personal information in a manner appropriate for the sensitivity of the information. We make every reasonable effort to prevent any loss, misuse, disclosure, or modification of personal information, as well as any unauthorized access to personal information and to protect any information stored on our servers, which are located in Ontario, Canada.
ORI and its vendors protect personal information in its custody and control through, for example:
Technical Safeguards: We employ technical safeguards, such as passwords and role-based access controls for information systems from which personal information may be accessed.
Physical Safeguards: We employ physical safeguards to protect personal information by locking filing cabinets, restricting physical access to offices and data centres, and shredding paper records we no longer need.
If you have asked ORI to prepare a Survey regarding a third party and would like additional information regarding it, contact your Advisor or ORI directly, who can provide the relevant non-personal information about the third party Survey Taker.
Right of deletion – If you wish to cancel your account or request that we no longer use your information to provide you services, please contact the Chief Privacy Officer with proof of identity. We will accommodate your request to the extent practicable, and to the extent that it does not otherwise conflict with any of our other obligations. We reserve the right to retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Right to opt-out of the use of your Personal Information – You may unsubscribe from receiving any of the ORI communications by selecting the appropriate option during account setup or modification once you are logged into your account. You may unsubscribe from receiving a newsletter by clicking on the unsubscribe link provided in the newsletter.
Rights of Survey Takers – Survey Takers have the choice to remain anonymous, meaning the responses will be used in aggregated form only, or “self-identify”, meaning the Survey Taker’s name will be associated with his or her responses. Self-identification is optional and Survey Takers who exercise this option acknowledge and agree that their responses will be shared with the Advisor and/or Customer.
COMPLAINTS AND DISPUTES
If you have a question or concern about any collection, use or disclosure of personal information by ORI, or about a request for access to your own personal information, please contact ORI’s Chief Privacy Officer.
Optimizer Reports Inc.