SurgeROI™ Privacy Policy

Privacy Policy

Effective as of: July 1, 2023

We believe the only good policy is one you can understand without a lawyer by your side, so we’ve worked hard to explain—clearly and in plain English—what we do, what information we collect, and why, so you can feel confident about using SurgeROI™.

If anything here is unclear, please reach out to us. We sincerely hope this helps you better understand our privacy practices, and how we operate. Thank you for joining the SurgeROI™ community!

A. SCOPE

Protecting your personal information is important to us. The following guidelines set forth our general privacy practices and principles that apply to information we collect. Our products and services are offered by SurgeROI™ Loyalty Inc. (“SurgeROI™,” “we,” “us,” or “our”).

This privacy policy applies to:

our products and services offered under the SurgeROI™ brand;
our websites and the products and services offered through those websites (including surgeroi.io and its subdomains (the “Site”); and

If you have questions or complaints regarding our privacy practices or principles, please contact privacy@surgeroi.io.

In simple Terms

Policies like these aren’t always the easiest to understand (or fun to read). We’ll do our best to make the legal language make sense on this side. The stuff along the left is what you’re agreeing to.

Third Parties‍

This privacy policy does not apply to products or services offered by third parties on or through our Site or services or products or services offered by, third-party websites, each of which have their own terms and conditions and privacy policies. You should carefully read each third party’s privacy policies and any terms and conditions applicable to the product or service you request. When you request products or services from such third parties, you give us permission to provide them with information about you necessary to fulfill or process your request.

Your use of social media features may use scripting or may require us to share your IP address and which page you are visiting to enable the feature to function properly. Social media features and widgets are either hosted by a business partner or hosted directly on our site, and your interactions with these features are governed by the privacy notice of the company providing it. Examples of these features are the Facebook “Like” button, the “Share This” button, and interactive mini programs that run on our services.

In simple Terms

Sometimes, we work with other companies and organizations to bring our customers an unbeatable experience. When this happens, their privacy policies apply and they’ll have access to some of your information, but only as much as is absolutely necessary to provide the service you want.

Special Note to Parents

‍Because of the nature of the services we provide, we do not market our services to children under the age of 13, nor do we knowingly collect information from children under the age of 13.

What Is Personal Information?

As part of providing products and services to you, we may collect information, including personal information, about you and your business when you use our services. “Personal Information” is data that can be used to identify a person individually. That’s what this policy is about – our collection, protection, use, retention, disclosure and other processing of Personal Information and your rights relating to these activities.

Categories of Personal Information Collected

The information we may collect includes, but is not limited to:

Contact Information (e.g., name, phone number, address, and email address);
Social Insurance Number or Social Security Number, and other government identification numbers (e.g., Employer Identification Number or Driver’s License Number);
Date of Birth;
Financial Information (e.g., income, revenue, assets, credits, deductions, expenses, and bank account information);
Payment Data (e.g., checking, debit and credit card account numbers, balances and payment history);
Health Information (e.g., health insurance status and financial information related to payment for healthcare services);
Geo-Location Information;
Website, Mobile Application, and Email Usage Data (e.g., interactions with a website, application or advertisement);
Device Information (e.g., internet protocol (IP) address, device type, unique identifier, app version, operating system, network data, and phone state);
Login Information;
Demographic Information;
Professional or employment-related information; and
Education information.

In simple Terms

We treat your personal information with the same respect we want our own to be treated with—and when you deal with finances like we do, there’s a lot of personal information involved. Here’s a list of exactly what we collect.

Aggregate Data

We also compile certain aggregate or anonymized data about our users. What is aggregate data? “Tim Smith buys a coffee at a coffee shop on Main Street” is the Personal Information of Tim Smith, but “20% of SurgeROI™ users buy coffee on Tuesdays” is aggregate data. We may use and disclose aggregated or anonymized information in our public statements and to identify individuals that may be interested in our Services.

In simple Terms

Understanding our customers is a huge part of building better experiences. To do this, we may look at and share customer data in summarized and anonymous forms, but rest assured, when we do, we cannot identify you or any customer personally.

Privacy Principles

Our privacy policy is based on the following ten fair information principles:

Accountability
Identifying purposes
Consent
Limiting collection
Limiting use, disclosure, and retention
Accuracy
Safeguards
Openness
Individual access
Challenging compliance

In simple Terms

The Canadian government provides these 10 principles on collecting, storing, and using Personal Information. By following this list, we cover all our bases so you can rest easy knowing your Personal Information is safe.

1. Accountability and Challenging Compliance

At SurgeROI™, the CEO is responsible for all things privacy. This includes our policies and procedures that are designed to keep your Personal Information safe.

If you have any questions or concerns about our privacy practices or this privacy policy, you can contact us at:

privacy@surgeroi.io‍
Privacy Officer
SurgeROI™ Loyalty Inc.
4000-421 7 Ave SW
CALGARY, AB, T2P 4K9

If you’re not satisfied with our response, you have the option of contacting the Office of the Privacy Commissioner of Canada.

In simple Terms

If you have any questions or concerns about your privacy, we have someone to listen and help. Here’s how you can get in touch with that person.

2. Identifying Purposes

SurgeROI™ collects, uses, discloses, and otherwise manages Personal Information in a variety of ways related to our Site and the services we provide. We’ve outlined these below. Your use of the services determines which categories of Personal Information we collect and use. For example, sweepstakes entry information is optional, unless you’d like to particiate in our sweepstakes, at which point we will need to collect KYC information to provide you with this service. Similarly, your email is optional, but if you’d like us to send and receive messages by email, this information becomes necessary.

In simple Terms

Many SurgeROI™ services and features simply wouldn’t work without some Personal Information. Here’s why and how that information is collected, stored, and used.

Purposes for which we Collect, Use or Store Personal Information

SurgeROI™ may collect, use, or store Personal Information for the purposes described below. You provide most of the Personal Information we collect. We also receive information through certain digital technologies when you interact with us. Finally, other companies may share information with us.

We collect information directly from you.

In order to provide you with the services you request, which may include the following:

We collect Personal Information directly from you when you use or interact with our Site or our services. This Personal Information may relate to you, your customers, your employees, or other individuals with whom you interact. This includes the Personal Information you provide as a part of setting up an online account, authenticating your identity, applying for or purchasing a product or service. It also includes information from documents you choose to upload to your SurgeROI™ account. If you choose not to provide certain information we request, we may be unable to serve you as our products or services may rely upon this information.
We may also collect Personal Information from third parties when you connect your SurgeROI™ account to them. These integrations may pull data into or share data out of SurgeROI™. In some cases, we use a service provider to connect you to a third-party service (e.g., when you connect an online Saas tool like Helpshift to your SurgeROI™ account). When you connect your SurgeROI™ account with a third-party service, their terms and policies apply.
We may also collect your name and email address from third parties when you sign up and login to our Site using single sign-on.

In simple Terms

We sometimes connect with other service providers to deliver the best products and services. When this happens, your information also falls under their terms and policies.

Our Site or services may offer publicly accessible blogs or community forums. You should be aware that any Personal Information you provide in these areas may be read, collected, and used by others who access them. To request removal of your Personal Information from our blog or community forum, you may contact us at privacy@surgeroi.io. In some cases, we may not be able to remove your Personal Information, in which case we will let you know if we are unable to do so and why.
To promote or offer you services, and to determine your eligibility for new products services we may offer from time to time.
To offer you products and services from our business partners.
To provide you with educational materials and guides relevant to the services you use.
To contact you for the purposes of service updates and system and account notifications.
To provide you with support in connection with the services.
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We collect information when you use our services.

We collect information and usage data whenever you interact with us, whether online, through a mobile application, or through an email. This data may include which websites you visit, what you click on, and when you performed those actions. These activities may be performed by us or a service provider acting on our behalf.
We use certain web and wireless technologies to collect this information. These technologies include cookies and web beacons. Please see Section B.7 for an in-depth discussion of these technologies and how to opt out.
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We collect information from other companies and government entities.

In accordance with their privacy notices, our business partners and unrelated third parties (including the IRS or CRA and credit reporting agencies) may share certain information about you with us.
We also collect information when you request services or information from us or companies with whom we have a business relationship, enter contests or sweepstakes, or complete surveys or polls.
To improve the security of our services, to protect your identity, and to protect your information, we may verify your personal information by matching the information you provide against other publicly available information that we obtain from identification verification companies.

In simple Terms

Personal Information would only appear in our blog or community if you posted it. If you’ve posted on our site and want it removed, just let us know. We can almost always remove it, and if not, we’ll let you know why.

How Do We Use Your Information?

We use your information to provide you with the products and services you request. We may also use your information, as permitted by law, including to service and report on your account; offer you relevant information, products, or services; and enhance our products and services. These activities may be performed by us or a service provider acting on our behalf.

Offer you products and services. We may use your information to contact you about products and services offered by us. This may include the delivery of newsletters or publications. We may also use aggregate information to offer our products and services.
Geo-Location Uses. We may use your location to assess the level of interest in our services in a particular area, and enhance the services we are providing you and other customers. You may at any time revoke our collection of this information by turning this off at the device level.
Mobile Devices. Subject to your control, our mobile services may request permission to dial a phone number, access your camera or photo library, access the internet, access your calendar, send you push notifications, wake/lock your mobile device, or authorize in-app purchases.
SurgeROI™ Account. We may use your information to set up an online account or authenticate your identity when you request certain services from us. We may use your email address as your online username. When you add documents to your SurgeROI™ account, SurgeROI™ might access them to assist you with coaching, or enhancing its services. We may retain your SurgeROI™ documents as allowed or required by law.
Security Enhancements. We may use your information to improve the security of our services, protect your identity, and protect your information.
Unique Identifiers. We may assign you a unique identifier when you use our services. This unique identifier allows us to match information collected through our other various products and services. Generally, we use this information to help us better understand your use of our products and services and to customize your experience and better serve you.
Calculators and Tools. When you use our calculators and other tools, we may collect non-identifiable data, such as the number of people that use a certain tool. We may also set cookies or clear gifs based upon your use, so you do not have to re-enter your information in a later visit and to help us customize offers and tools to your particular interests. For our calculators and other tools that require registration or ask for your contact information, we may contact you directly with relevant services and offers.

Automated Decision Making. We may use automated decision making with respect to your Personal Information for risk-related measures and to help protect your account and SurgeROI™ from fraud.

We do not sell your Personal Information with other companies.

In simple Terms

We will not sell your details, ever.

How We Disclose Information.

We may disclose your Personal Information among the companies, to our other affiliates, and to third parties with whom we have a written contract limiting the use and disclosure of your Personal Information (“service providers”), as directed by you to provide the services or products you request or as permitted by law. We may share your Personal Information to support the products and services you request or provide you with information on products and services that may benefit you.

In simple Terms

There are times when personal information does need to be disclosed. You have the right to know about these situations, so we’ve listed them here.

For example:

SurgeROI™ Companies We may provide Personal Information to companies related to us by common ownership or control. These companies may use this information to support the products and services you request or market additional products and services to you. These activities may include providing customer service, processing transactions, or offering other SurgeROI™ products and services. If you do not want us to share your Personal Information with companies related to us by common ownership or control for marketing purposes, please contact privacy@surgeroi.io.

Business Partners. We work closely with a variety of business partners that are not SurgeROI™ companies (e.g., our bank partners, or our telephony and email partners). Pursuant to our vendor management program, we require all business partners to have written contracts with us that require them to safeguard your information and prohibit them from selling, retaining, using or disclosing your Personal Information for any purpose other than for the specific purpose of performing the contract.

In simple Terms

Online products like SurgeROI™ need to interact with other business partners in order to work properly. When this involves sharing personal information, we’re vigilant about ensuring the information is managed securely and responsibly.

Service Providers. We may disclose your Personal Information to service providers who provide services on our behalf. For example, we may use service providers to host our website and to process payments. We may also share your Personal Information, and a record of any transactions you conduct on our website or offline with us with a third-party advertising partner and its service providers to deliver advertising tailored to your interests when you visit certain other websites. Data shared for tailored advertising is made pseudonymous. Pursuant to our vendor management program, we require all service providers to have written contracts with us that require them to safeguard your Personal Information and prohibit them from selling, retaining, using, or disclosing your Personal Information for any purpose other than for the specific purpose of performing the contact. Your Personal Information may be maintained and processed by these third parties in other jurisdictions. We use service providers in Canada and the United States. When your information is in another jurisdiction, it will be subject to their laws. We only share the information these service providers need to perform the service and we don’t authorize them for any other use or disclosure of Personal Information.

In simple Terms

We also occasionally need to share personal information with service providers. This is especially true for complicated tasks like transferring money electronically. We take the same high level of caution, and ensure the information is used only for the purposes needed.

‍Marketing Arrangements. We may provide Personal Information to companies with whom we have a joint marketing arrangement. Pursuant to our vendor management program, we require all marketing service providers to have written contracts with us that require them to safeguard your Personal Information and prohibit them from selling, retaining, using, or disclosing your Personal Information for any purpose other than for the specific purpose of performing the contract. We do not share your Personal Information with third parties for their marketing purposes without your consent or without providing you with the opportunity to opt out of such sharing.

In simple Terms

We require all marketing service providers to safeguard your personal information. They are not allowed to sell your information or use it for additional purposes without your consent.

Persons Who Acquire Our Assets or Business. If we sell or transfer any of our business or assets (including insolvency or bankruptcy proceedings), certain information about our customers may be a part of that sale or transfer. In the event such sale or transfer results in a material change to this privacy policy, we will notify you. The notification procedure will be the same as the procedure we use to notify you of a change to this privacy policy as described below.

In simple Terms

If the ownership of SurgeROI™ changes, customer information may be included in the transfer of ownership. Rest assured, we’ll let you know if that change causes material updates to these policies.

Responses to Legal Requests. We may disclose your Personal Information when we have a good faith belief that such disclosure is required or permitted by law pursuant to a legal request. This may occur in connection with a court order, legal process, or other judicial, administrative or investigative proceeding that produces a request for information from us. In certain situations, we may be required to disclose your information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

In simple Terms

When laws require us to share customer information with the proper authorities, we’re obligated to do so.

Protection of SurgeROI™ and Others. We may disclose your Personal Information when we believe that disclosure is necessary to protect either your or our rights and safety. We may disclose your Personal Information to federal, state, provincial, or local officials in order to, and only to the extent necessary, inform the official of activities that may constitute, or may have constituted, a violation of any criminal law or to assist the official in investigating or prosecuting a violation of criminal law.

In simple Terms

Like the point above, information may be shared with government authorities when legally required.

Aggregate Data. We may disclose aggregate information compiled using information that does not identify you individually or personally. This may include, for example, the total number of visitors from a particular geographic area or the average user age.

In simple Terms

Some summarized, anonymous information may be shared publicly, but could never be connected to individual customers.

Third-Party Online Advertisements. We may allow third parties to place advertisements for their products or services on our website. If you interact with these advertisements, you must disclose your personal information (e.g., IP address) to these advertisers. If you click on a third-party advertisement, you will be directed to their website and your interactions with them will be governed by their privacy notice.

In simple Terms

If you interact with a third-party ad, your personal information will be disclosed to the advertiser and will be subject to their privacy policy.

3. Consent

Your Choices

Some United States jurisdictions, such as California, Colorado, Connecticut, Virginia, and/or Utah, may give you a right now, or in the future, to make the following choices regarding your Personal Information.

Access To Your Personal Information. You may request access to your Personal Information or confirmation that we have Personal Information about you. In certain limited circumstances, you may also request to receive access to your Personal Information in a portable, machine-readable format.
Changes To Your Personal Information. You may ask us to correct Personal Information we have about you that is inaccurate or incomplete. Note that we may keep historical information in our backup files as permitted by law.
Deletion Of Your Personal Information. You may request that we delete your Personal Information. If required by law, we will grant a request to delete your Personal Information, but you should note that in many situations we must keep your Personal Information to comply with our legal obligations, resolve disputes, enforce our agreements, or for other business purposes.
Opt-Out of Sharing for Cross-Contextual Behavioral Advertising. You may request that your Personal Information not be shared for the purpose of cross-contextual behavioral advertising.
Online Tracking. We do not currently recognize the “Do Not Track” signal.
Emails. Where permitted by law, we may use your Personal Information to communicate with you about products and services. If at any time you wish to limit your receipt of promotional communications, you may contact us at privacy@surgeroi.io, or follow the unsubscribe instructions included in each marketing communication you receive from us.
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Please note, not all of the rights described above are absolute, and they do not apply in all circumstances. In some cases, we may limit or deny your request because the law permits or requires us to do so, or if we are unable to adequately verify your identity. We will not discriminate against individuals who exercise their privacy rights under applicable law.

Submitting the Personal Information of Others

When you submit the Personal Information of your customers or employees to us, you are responsible for informing such customers and employees about SurgeROI™, and for obtaining any necessary consent or authority from them, including informing them that SurgeROI™ operates within Canada and utilizes service providers within the United States and Internationally. In addition, your Personal Information will be accessed by SurgeROI™ employees outside of Canada and the United States for business purposes.

You may also choose to refer someone to our Site or through our referral program. We may ask for that person’s name and contact information, including email address. We will send them a single invitation email to the address you provide. Please ensure that you only submit email addresses of individuals or businesses with whom you have a relationship and who would want to receive the message.

Closing your SurgeROI™ Account

At any time and without penalty, you can close your SurgeROI™ account and stop using our services. Please ensure you complete the account closure process which includes a confirmation email. Otherwise, your account may not be closed.

In simple Terms

We’d be sad to see you go, but if you do, we won’t make closing your account a hassle. Just don’t forget the confirmation email to make it official.

How May I Opt Out of Email Communications?

You may choose to limit our use or our ability to share your information in certain circumstances. Our ability to offer you certain products and services and your experience may be affected by your choice. If at any time you wish to limit our sharing of your Personal Information with our affiliates or nonaffiliates, you may contact us at privacy@surgeroi.io. You may, however, continue to receive email communications related directly to the services and products you purchase, such as payment receipts.

Certain non-commercial communications may still be sent to you that are required to provide you with our services. For example, system notifications, major product changes, changes to our Terms of Use or Terms of Service, or other news that we believe will materially affect how you interact with SurgeROI™.
The only way to completely stop all emails from SurgeROI™ is to close your account as outlined above.
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Where permitted by law, we may use your Personal Information (subject to your consent, where required) to communicate with you about products and services available through SurgeROI™ or our business partners. If at any time, you wish to limit your receipt of such communications, you can opt-out of such commercial email communications by clicking on the unsubscribe link in such emails, via the Email Preferences settings in your account, or by contacting us at privacy@surgeroi.io. At your request and subject to the limitations below, we will make reasonable efforts to limit all such marketing communications to you. We will respond to requests within a reasonable timeframe.

The above paragraphs only apply to the Personal Information we obtain through your use of our services covered by this privacy policy. You may still receive offers from us or other SurgeROI™ companies where they obtain your contact information through other sources.

Please see Section B.7 for information on how to opt out of various web and wireless technologies we use.

In simple Terms

We like to keep in touch and promise we won’t overdo it. Still, if you’d ever like to opt-out, we’ve made it easy.

Heads up: If you opt-out of our marketing emails, we may still send you important, non-marketing messages, related to your SurgeROI™ account.

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4. Limiting Collection

SurgeROI™ only collects the Personal Information necessary to provide the services to you. The services you use will determine most of the Personal Information SurgeROI™ collects. We’ll also provide you with the option of sharing additional information to enhance your SurgeROI™ experience.

SurgeROI™ may also use third-party services to supplement or enrich our understanding of our customers. This includes cross-referencing information like a name, business name, email address or IP address in third-party databases and using the information there to improve our understanding of you and your business.

In simple Terms

We only collect the personal information we need to deliver the services you want. What we collect depends on which services you use.

5. Limiting Use, Disclosure, and Retention

We will use and disclose your Personal Information as described in this policy. Some SurgeROI™ employees who have access to your Personal Information outside of Canada and the United States. Regardless of where a SurgeROI™ employee is physically located, your Personal Information is protected by the safeguards described in this privacy policy.

In accordance with applicable laws, we keep your Personal Information for as long as needed to serve you, maintain your account, as needed to operate our business, or to improve our offerings or develop new ones.

We retain your information (including geo-location data) for as long as your account is active or as needed to provide you with services. We may retain or use your information as necessary to comply with our policies, legal obligations, resolve disputes, and enforce our agreements. To be clear, that means we’ll retain your Personal Information while you have an active account, and afterward if we need to do so to meet our legal obligations. If you choose to close your SurgeROI™ account, we will destroy your Personal Information within sixty (60) days unless we are otherwise legally obliged to keep it longer consistent with our retention policies or if we determine it is necessary to defend against legal claims.

Please see Section A.9 for information on how to update or delete your information.

In simple Terms

We take our responsibilities about using, disclosing, and storing your personal information seriously. Unless we’re legally required to keep it for longer, your information will be destroyed within sixty (60) days of closing your account.

6. Accuracy

SurgeROI™ relies on you to provide us with information that is accurate and complete. We provide you with the mechanisms within your SurgeROI™ account and rely on you to keep your information up to date. You can request updates or corrections of any inaccuracies in your Personal Information at any time by contacting us at privacy@surgeroi.io. We will respond to your request within a reasonable timeframe.

In simple Terms

It’s up to you to ensure the information you provide SurgeROI™ is accurate. If you need to make changes, just let us know.

7. Safeguards

The security of your Personal Information is important to us. We utilize administrative, technical, and physical safeguards to protect your information. If you have any questions about the security of our services, you can contact us at security@surgeroi.io. We protect the information submitted to us, both during transmission and once we receive it. Nevertheless, no method of transmission over the Internet, or method of electronic storage is 100% secure. Therefore, we cannot guarantee its absolute security.

We maintain administrative, technical, and physical safeguards that comply with applicable law and federal standards and that are designed to restrict access to your information. These safeguards include administrative controls (things like policies, procedures, and training), technical controls (things like encryption, firewalls, and secure coding frameworks), and physical controls (secured hosting environments).

If we collect sensitive information (such as your SIN or SSN), we will encrypt the transmission of that information using Transport Layer Security.

If we share your information with our service providers, we require all service providers to have written contracts with us that require them to safeguard your information and prohibit them from selling, retaining, using or disclosing your information for any purpose other than for the specific purpose of performing the contract.

We may notify you by email, mail, or telephone in the event of a data security incident, and where permitted by law.

In simple Terms

From policies to software to physical measures, we do everything we can to protect your information. If you’d like more details, feel free to reach out.

We ensure that any third party acting on our behalf maintains reasonable and appropriate safeguards in respect of your Personal Information. Additional information about our third parties’ privacy practices is available upon request.

In simple Terms

When we work with another partner, we make sure they’re vigilant about protecting your information too.

You are also responsible for helping to protect the security of your Personal Information. For instance, never give out your email account information or your password for the services to third parties. Our team will never request your password or PIN, and we ask that you never post account or credit card numbers to our support channels.

In simple Terms

Here are some best practices to help you keep your information secure on your end.

8. Openness

This policy outlines our privacy practices. If you have questions about it, please contact our Privacy Officer at privacy@surgeroi.io.

In simple Terms

We have someone to help if you have any questions about this document, so reach out.

9. Individual Access

You may access, update and correct inaccuracies in the Personal Information in our custody or control at any time, subject to limited exceptions prescribed by law. You may contact us regarding your information by contacting privacy@surgeroi.io. If you are a SurgeROI™ user, you may access your information through your SurgeROI™ account and, where available, update that information. You can download or export data you input into the Site at any time, correct inaccuracies, or delete information, by simply logging in to your SurgeROI™ account and making the necessary changes.

When you update or delete your information, we may maintain a copy of the information in our records. Additionally, if you request that we permanently delete your account or information, we may still retain and use your information as necessary to comply with our legal obligations.

If an unauthorized profile has been created about you, please contact us at privacy@surgeroi.io to request to have it deleted. We will respond to your request within a reasonable timeframe.

In simple Terms

We’ve made it easy for you to access and update your information on your own by logging into your account. You’re free to update or delete your information. We’ll only hang on to anything we legally need to keep.

You can also request access, corrections or updates to all your Personal Information, including information not available through your account, by contacting us as set out in this privacy policy. We may request certain Personal Information for the purposes of verifying the identity of the individual seeking access to their personal information records.

In simple Terms

Not all information can be edited by you in your account. For those cases, here’s how to get it done.

B. ADDITIONAL DETAILS

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1. Public Content and Social Media

SurgeROI™ may have public forums and blogs. Any information submitted there may be read and collected by anyone. You may request removal of Personal Information from forum or blog posts and comments by contacting us at privacy@surgeroi.io.

In simple Terms

When you post or provide information somewhere like a comments section or forum, other people may see it. If you’d like this information removed, get in touch and we’ll get it done.

If you provide us with a testimonial, with your consent we may post it on our Site or in other materials and media, along with your name. If you want your testimonial removed, please contact us at privacy@surgeroi.io.

You may engage with us through social media sites. When you engage with us on these sites, we may have access to certain information about your account (e.g., name, username). These sites may collect your IP address, how you’re engaging with us, and may use cookies to enable the site to function properly. We may use this information to personalize your experience and to provide you with other products or services you may request.

In simple Terms

Same thing goes for testimonials you may have provided. If you’d like it removed, just ask.

We may also use services provided by third-party platforms (such as social networking sites) to serve targeted ads on such platforms to you or others, and we may provide a hashed version of your email address or other information to the platform provider for such purposes. To opt-out of the sharing of your information with such platforms, please send an email to privacy@surgeroi.io.

In simple Terms

When third-parties are involved, we keep your details anonymous

2. General Data Protection Regulation

We process your Personal Information to provide the products and services you request and for our legitimate business interests, including marketing.

Our services are hosted on servers located in Canada and the United States. We also use service providers located in Canada and the United States to provide you with our services. The transfer of your Personal Information, and the information you input into our services, to Canada and the United States is necessary to deliver our services. Please be aware that the laws in Canada, Norther Europe or the United States may not provide the same level of protection to your personal information as your home country.

In simple Terms

Most of what we do happens in Canada, Norther Europe and the United States. So, the information you provide will likely pass through these jurisdictions, unless otherwise prohibited.

If you are accessing our services from the European Union, you may have certain rights regarding the processing of your Personal Information. For instance, if the information you provide contains special categories of personal data, we will only process it with your explicit consent, which can be withdrawn at any time. You may have the following additional rights:

You have the right to access and correct your information.
You have the right to obtain erasure of your information, object to or restrict processing activities related to your information, or withdraw your consent to the processing of your information after you have provided it.
You have the right to obtain a copy of your information in a structured, commonly used, machine readable format.
You have the right to lodge a complaint with your local supervisory authority regarding our processing of your information.

To exercise your rights, or if you otherwise have questions about the processing of your personal data, you may contact us at privacy@surgeroi.io.

In simple Terms

The European Union provides residents with unique rights and responsibilities.

3. Visiting the Site

In general, you can visit the Site without telling us who you are or submitting any Personal Information. However, we collect certain information and usage data whenever you interact with us, whether online, through a mobile application, or through email. We and/or our service providers (such as Google Analytics) collect which websites you visit, what you click on, when you performed those activities, your IP (Internet protocol) addresses from all visitors to the Site and other related information such as page requests, browser type, operating system, and average time spent on our Site. This information is used to help us understand the activity on, and to monitor and improve, our Site.

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To help make our app and website the best they can be, we look at information on how these tools are used.

4. Use of Web and Wireless Technologies (including Cookies, Tags, and Web Beacons)

We, and our service providers, use commonly used technologies, such as cookies or similar technologies, to remember you and to personalize your experience with features and advertisements. We, and our service providers, use these technologies to help us know your usage patterns, track your preferences, analyze how you use our services, administer the website and mobile application, and gather demographic information about our user base, as a whole. We may receive reports on an individual or aggregate basis based on these technologies. You may opt-out of some of these technologies.

Cookies. Cookies are small alphanumeric identifiers that a web server transfers to your computer or mobile device via your Internet browser. When your Internet browser visits a web page, a cookie is set with a unique number. This number is recorded in a small text file that is transmitted to your computer or mobile device and stored in the cookie directory of your hard drive. Then, when you visit each web page or component of our service or mobile application on which the cookie technology is enabled, the website or mobile application can recognize your browser as a unique user.

The purpose of cookies is to make your experience more convenient and personal. For example, knowing what products interest you, helps us tailor your experience to meet your needs. We also have service providers that use cookies on our website to facilitate measurement and reporting. We also use cookies for session tracking to make it possible to navigate the secure environment inside our website and application. These cookies (1) may let us know who you are, (2) are necessary to access your account, and (3) will give us information that we can use to personalize our website and application according to your preferences. You can control the use of cookies in your browser. If you disable cookies, you will not be able to access your account or take advantage of all of the features of the website and application.

We, or service providers acting on our behalf may use cookies and similar tracking technologies to collect information and infer your interests for interest-based advertising purposes. If you would prefer to not receive personalized ads based on your browser or device usage, you may generally express your opt-out preference to no longer receive tailored advertisements. Please note that you will continue to see advertisements, but they will no longer be tailored to your interests.

To opt out of interest-based advertising by participating companies in the following consumer choice mechanisms, please visit the Digital Advertising Alliance (DAA)’s self-regulatory opt-out page, the Digital Advertising Alliance of Canada’s self-regulatory opt-out page, the mobile application-based AppChoices download page, the European Interactive Digital Advertising Alliance (EDAA)’s consumer opt-out page, or the Network Advertising Initiative (NAI)’s self-regulatory opt-out page.

In the mobile environment, most mobile operating systems offer device-based opt-out choices that are transmitted to companies providing interest-based advertising. To set an opt-out preference for a mobile device identifier (such as Apple’s IDFA or Android’s GAID), visit the device manufacturer’s current choice instructions pages, or read more about sending signals to limit ad tracking for your operating system here.

Please note that these settings must be performed on each device (including each web browser on each device) for which you wish to opt out, and if you clear your cookies or if you use a different browser or device, you will need to renew your opt-out preferences.

You may also adjust your browser settings to accept or deny all cookies, or to request your permission each time a site attempts to set a cookie. Although cookies are not required for some parts of our services, our services may not work properly if you disable cookies entirely. Clearing cookies from your web browser may revoke a prior opt-out you have selected.

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Cookies, while delicious, are also a helpful way of providing you with a smooth experience. You can turn cookies off in your browser, but the site may not work properly if you do.

Local Storage Objects HTML5. We, and third parties with whom we partner to provide certain features on our website or to display advertising based upon your web browsing activity, use HTML5 to collect and store information. Various browsers may offer their own management tools for removing HTML5.
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Clear GIFs or Web Beacons. We employ a software technology called clear GIFs (also known as pixel tags or web beacons), that help us better manage content on our websites by allowing us to understand usage patterns, fix issues, and improve the products and services offered to you on our websites. We may use clear GIFs in our emails to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. These activities may be performed by us or a service provider acting on our behalf.
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Log Files. Like most websites, we use log files. Information collected in log files may include IP addresses, unique device IDs, browser type, Internet Service Provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), platform type, date/time stamp, and number of clicks. We utilize this information to analyze trends, administer the site or mobile application, track user movement in the aggregate, and gather broad demographic information for aggregate use.
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Traffic Data. We collect information relating to traffic on our website. We may collect and record information on pages visited, mouse movements and clicks, scrolling activity, keystroke data that you voluntarily enter on our website, HTML data on a page visited, IP address or information your browser provides to our web server, such as browser type, operating system, average time spent on our website or mobile application, language, screen resolution, referring URL, etc. Our collection of website traffic information is anonymized and does not include personally identifiable information. We utilize this data to improve our website and the products and services offered to you.
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Mobile Device Information. We may record data from your mobile device such as Apple IDFA, device brand and model, general characteristics of your device, and other device IDs.
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‍Mobile Analytics. We use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personal information you submit within the mobile application.

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Although we track web activity, we only collect information as required and to improve what we offer. You can opt out of some of these technologies.

How do we respond to web browser “do not track” signals?

We treat the Personal Information of everyone who comes to our Site in accordance with this privacy policy, whatever their “do not track” setting. While we do not respond to web browser “do not track” signals, we give you choices about receiving promotional offers from us or third parties. You can exercise your choices as described in this privacy policy.

If you are located in California, you may prevent us from storing cookies on your device to enhance site navigation, analyze site usage, and assist in our marketing efforts by declining cookies in the cookie banner presented to you when you visit our website.

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Although we track web activity, you can choose to receive or not receive promotional offers from us.

5. Notification of Privacy Policy Changes

We may update this privacy policy to reflect changes to our information practices. If we make a material change to this privacy policy, including a material change in the way we use any Personal Information, we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on our website at least 30 days prior to the change becoming effective. We encourage you to periodically review our privacy policy for the latest information on our privacy practices.

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It’s a good idea to check in on this policy here and there for updates. If the updates are significant, we’ll let you know.