ATCC Privacy Policy

Agriculture Technology Commercialization Centre Corporation, a not-for-profit corporation, and its Affiliates (“ATCC”, “we”, “our”, or “us”) values our customers, including you (“you” or “your”) and we respect your privacy and personal information which is information about an identifiable individual (as defined by applicable privacy or data protection laws). This privacy policy (this “Policy”) applies to your use of our websites, software, and/or services (“Products”) and describes the kinds of personal information we collect about you, how we use it, how we protect it, and under what circumstances we share it with third parties. This Policy also describes the decisions you can make about your personal information. You may require us to change, amend, or delete the personal information that you have provided to us at any time. “Affiliates” means any entity directly or indirectly controlling or controlled by, or under control with, ATCC.

Your access to and use of our Products and services is subject to our Terms and Conditions. Any capitalized terms used but not defined in this Policy have the meanings provided in the Terms and Conditions.

If this Policy changes in the future, we will post an updated version on our website at www.agregkit.com (the “Website”). We recommend that you check this Website periodically in order to review our current Policy. You can tell if this Policy has changed by checking the effective date that appears at the bottom of this Policy. Depending on the circumstances, we may also decide to send you a notice (in other ways in our discretion, such as via email or other contact information you have provided) that the Policy was changed. If you continue to use our Products after the Policy changed or notice of the change has been given, you will be deemed to have accepted such changes.

Consent

By using, registering to or otherwise accessing our Products, Website and/or other services (collectively, the “Services”), you agree to this Policy and give your explicit, informed consent to the collection, use and processing of your personal data in accordance with this Policy. If you do not agree to this Policy please do not visit, use, register to, or otherwise access any Services.

You may withdraw your consent at any time, unless such consent would frustrate the performance of a legal obligation. Your withdrawal or refusal to grant consent may restrict our ability to provide the Services.

There are limited circumstances in which we may collect, use or disclose personal information without your consent. They are:

1. when the collection, use or disclosure of personal information is permitted or required by law;
2. in an emergency that threatens an individual’s life, health or personal security;
3. when the personal information is available from a public source;
4. when we require legal advice from a lawyer;
5. for the purposes of collecting debt;
6. to protect ourselves from fraud; or
7. to investigate an anticipated breach of an agreement or a contravention of law.

How We Collect Personal Information

Like most website operators, we collect personal information about you from a variety of sources. We only collect information by lawful means, with your knowledge and consent. We also let you know why we’re collecting it and how it will be used. We collect information from you in the following ways:

1. directly from you (when you sign up for or use our Services);
2. from our business partners including members of the Agri-Technology Commercialization Centre, Oilseed Innovation Partners and Ontario Agri-Food Technologies, goverment offices, and third party services providers and sources; and
3. automatically from devices that you use to connect to our website and apps

Information We Collect

When you use our Products or the Services, we may collect the following types of information:

1. account information: when you use our Products you may need to create an account with us. In order to create an account, you will need to provide us with a complete profile: login credentials (which include your username and password), the company name and address, postal address, your name, email address, phone number, fax number, and cellphone number, and in certain circumstances, gender and identification as minorities;
2. authentication information;
3. communications with us;
4. transaction information and information/details related thereto;
5. general usage data: when you use our Products or Services we collect information about your interactions, such as searches, engagement, language preferences, how long you use our Products per regulatory investigation, how long you use our Product in each session, features you use in our Products, and how long you use our Products overall;
6. purchase and payment information: we may collect payment information to process, administer, manage, and fulfill the purchases you make. For example, we may collect your name, email address, account information, what is ordered, the date and time of the order, the quantity and price of the order, whether payment was made, method of payment, purchase history, and if you re-ordered;
7. location information: when you create an account with us, we collect your postal address information which may indicate your location;
8. third party services information: if you link to or connect with third party services, they may send us information, all of which will be controlled by such third party;
9. log data: this information includes details about how you use the Services, IP addresses, access times (time and date of your visit), time spent on the page, your browser type and version, device information, pages you view before and after using the Services, links to third party applications, and hardware and software information;
10. cookies: our site uses “cookies” which enables us to remember you and understand and save your preferences, a cookie is a string of information that a website stores on your computer, and that your browser provides to the website each time you return. We use cookies to help us identify and track visitors to our sites, their usage of the website, and their website access preferences. If you do not wish to have cookies placed on your computer you should set your browsers to refuse cookies before using our websites. If you do this, the drawback is that certain features of our websites may not function properly and this may also block cookies for any other website you visit;
11. quality assurance and customer service: your customer service emails with us may be logged, for quality assurance and customer service purposes such as to assist in addressing your inquiries,  troubleshooting, training and analytics to identify trends and make improvements to our Products and customer service. As part of the logging of the emails, we will collect information like the identity of the sender of email, the date and time of the email, and the subject and resolution of the issue; and
12. other sources: to the extent permitted by applicable law we may receive additional information about you, such as demographic data or fraud detection information and warnings, or other information about you from partner networks.

Log data

When you visit our websites, our servers may automatically log the standard data provided by your web browser as provided for above. This data is considered “non-identifying information”, as it does not personally identify you on its own. We may also collect data about the device you are using to access our websites. This data may include the device type, operating system, unique device identifiers, device settings, and geo-location data. What we collect can depend on the individual settings of your device and software. We recommend checking the policies of your device manufacturer or software provider to learn what information they make available to us.

Some of this information would not by itself identify you to us or be personally identifiable and is therefore considered non-personal information. If we combine any such non-personal information with other personal information available to us, the combined information will be treated as personal information in accordance with this Policy.

Our Use of Information We Collect

We use your personal information for the purposes identified in this Privacy Policy at the time of collection or for a purpose related thereto, include to develop and provide the Services. We may use a combination of identifying and non-identifying information to understand who you are, how you use our websites and Services, and how we may improve your experience of our websites in future. Specifically we use personal information for the following purposes:

1. verifying identity and authenticating information;
2. registration;
3. to provide the Services and operate our business;
4. to understand and meet your needs and preferences, and/or to provide you with our Products, for example:
   • for purposes related to the billing, activation, provision, maintenance, support, trouble shooting, resolving of disputes, deactivation, upgrade, or update of Products;
   • to process and fulfill your order, send you emails to confirm your order status and shipment, send you Products or goods you order, and allow you to pay for Products and goods you order;
   • to ensure Products are technically functioning as intended and to help identify and troubleshoot issues;
   • to fulfill or enforce any agreements or notices we provide and are associated with a particular Product (“Notices”);
   • to manage or respond to your inquiries or complaints;
   • establishing and maintaining relationships with our users;
5. to develop new and enhance existing Products including to communicate with you about them using various means, for example to make available or send to you upgrades or updates, or notices of upgrades or updates of Products;
6. to send email notifications and reminders related to the Services, including updates about the ATCC, AgRegKit or Bioenterprise Corporation, our activities, services and program offerings and news that may be made available to you (which you may opt out of);
7. sending newsletters or other marketing information and from time-to-time, promotional content that we believe may be of interest to you - if you wish to opt out of receiving any of this content, you can follow the “unsubscribe” instructions provided at the bottom of the email correspondence from us;
8. to manage and develop our business and operations, for example:
   • to detect, monitor, investigate, mitigate or attempt to prevent fraud and technical or security issues or to protect our property;
   • to allow for business continuity and disaster recovery operations;
   • to enforce our legal rights;
   • for statistical purposes;
9. to optimize experiences by performing analytics and conducting research;
10. to conduct investigations;
11. for resolving disputes and enforcing agreements and our policies; and
12. to meet and comply with legal and regulatory requirements and to respond to emergency situations, for example:
    • to respond to court orders, warrants or other lawful requests or legal processes;
    • to provide emergency assistance in situations that may threaten the life or physical safety of you or others; or
    • for any other purposes for which you have consented, such as those that may be set out in Notices, and other purposes as permitted or required by any applicable law.

Disclosure of your Personal Information

We may disclose personal information to fulfil the purposes identified in this Policy, and for purposes related thereto, and to provide the Services, including as follows:

1. within ATCC;
2. with our financial, insurance, legal, accounting or other advisors that provide professional services to us (third party providers have their own rules and privacy policies and we encourage you to review these rules and policies);
3. if we have your consent;
4. with third parties involved in providing funding to ATCC which may include Agriculture and Agri-Food Canada (AAFC) and Ontario Ministry of Agriculture and Rural Affairs (OMAFRA) (third party providers have their own rules and privacy policies and we encourage you to review these rules and policies);
5. with third parties involved in sponsoring and/or providing our Products to you which may include Bioenterprise Corporation, Soy 20/20 Corporation and Ontario Agri- Food Technologies Corporation, or third party providers (third party providers have their own rules and privacy policies and we encourage you to review these rules and policies);
6. with other third party services providers such a Google Analytics and third party providers (we may use third party service providers to provide the Services and we share your information with them so they may carry out tasks on our behalf, each provider has its own rules and privacy policies and we encourage you to review these rules and policies);
7. with any other of our business partners who carry out tasks on our behalf (each provider has its own rules and privacy policies and we encourage you to review these rules and policies);
8. with your employer, if your employer has provided you with access to the Products (we may share any and all information about your use of the Products with your employer or its agents);
9. certain information may be shared with third parties or published when you follow links to third party websites, we do not own or control these third parties and when you interact with them you may be providing information to them directly - such parties will have their own rules and policies in respect of the collection, use and disclosure of personal information and we encourage you to review these rules and policies;
10. certain aggregated and anonymized information may be shared publically - we do not disclose the specifics of personal information publicly, but we may share aggregated and anonymous versions of this information, for example, in website and customer usage trend reports;
11. publically, for example, information you choose to share may be visible to the public and may be indexed through third party search engines – we do not control the practices of third party search engines;
12. as necessary to complete any transactions while using our Products;
13. to respond to a subpoena, order, legal process, or government request;
14. to protect, establish or exercise our legal rights or defend against legal claims;
15. to investigate, detect, suppress, prevent or take action regarding illegal or prohibited activities, suspected fraud, situations involving potential threats to the reputation or physical safety of any person;
16. as otherwise required by law, for example and without limitation, pursuant to an access to information request; or
17. if we are to be sold, merged, or amalgamated or substantially all of its assets are to be sold or disposed of, your personal information may be transferred to a potential purchaser if, and to the extent necessary, it is required for the purposes of deciding whether to proceed with the proposed transaction and completing it. If such a sale, merger, acquisition, or disposal is completed, we will use reasonable efforts to direct the transferee to use personal information you have provided to us in a manner that is consistent with this Policy. Following such a sale or transfer, you may contact the entity to which we transferred your personal information with any inquiries concerning the processing of that information.

Aggregated and Anonymized/De-Identified Information

Notwithstanding anything to the contrary contained in this Policy, as provided for above, we may remove personal identifiers from your information and maintain and use it in a de-identified form that may be combined with other information to generate aggregated information. Such de-identified and/or aggregated information will be deemed to be owned by us and we shall have unrestricted title, rights, and interest to the de-identified and/or aggregated information which may include, without limitation, the right to use, distribute, transmit, transfer, license, trade, rent, share, assign, and sell the de-identified and/or aggregated information. We will retain your personal information as long as necessary for the fulfillment of the identified purposes or as otherwise necessary to comply with applicable laws.

You may update your communication preferences anytime by writing us at info@agregkit.com.

Your Decisions About Your Personal Information

At any time you can contact us to: stop receiving emails from us; review the personal information held by us in connection with your account; withdraw your consent for our use and disclosure of your information; request a list of third parties to which we may have provided your personal information; close your account; and amend your personal information, by writing to us at ATCC, Suite 200, 120 Research Lane, Guelph ON N1O 0B4. You can always unsubscribe from receiving promotional emails from us by simply clicking the “unsubscribe” link provided at the bottom of every promotional email from us. If you contact us to do any of the things listed above, we may require you to provide sufficient personal information to allow us to identify you and tell you about the existence, use and disclosure of your personal information and this personal information will only be used for this purpose. If you contact us about your personal information, we will respond to your request within a reasonable time and at minimal cost or no cost to you in accordance with applicable laws. If a request is refused, you will be notified of the refusal in writing and provided with reasons for the refusal.

Generally, you may withdraw at any time your consent for us to collect, use, and disclose your personal information in accordance with this Policy, subject to legal or contractual restrictions and reasonable notice. As such, we may continue to collect, use, and disclose your personal information as may be required to provide you with our Products, and to the extent that we are contractually obligated to do so or as necessary to enforce any contractual obligations you may have with us. If you refuse to provide us with the information we require or later contact us to withdraw your consent for us to use and disclose your personal information, we may no longer be able to provide you with our Products.

Data Processing, Storage and Access

The personal information we collect is stored and processed in Canada, or where we or our partners, affiliates and third-party providers maintain facilities. We only transfer data within jurisdictions subject to data protection laws that reflect our commitment to protecting the privacy of our users.

For customers and subscribers from the European Union, please note that personal information that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area.

We only retain personal information for as long as necessary to provide a service, or to improve our Services in future. While we retain this data, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorised access, disclosure, copying, use or modification.

You may request access to your personal information or request to know how we use it or to whom it has been disclosed, subject to limited exceptions prescribed by law. Requests should be made in writing. We will respond to requests within 30 days or provide notice if we require longer. Fees may be charged to access information, but you will be notified of such in advance so you can choose whether or not to proceed. If you request your personal information be deleted, or where your personal information becomes no longer relevant to our operations, we will erase it from our system within a reasonable timeframe. If a request is refused, you will be notified of the refusal in writing and provided with reasons for the refusal.

Security

We aim to provide you with a safe experience. We have in place certain physical, technical, and administrative safeguards designed to appropriately protect the security and privacy of your personal information against loss, theft, and unauthorized access, disclosure, copying, use, or modification. Please note, however, that we cannot guarantee that the measures we maintain will guarantee the security of the information.

We only retain personal information for as long as necessary to provide a service, or to improve our Services in future.

We limit access to your personal information within ATCC to individuals with a need to know.

Links to Other Sites

We provide links on our Website to third party sites we think you will enjoy. These sites operate independently of us and may have established their own privacy and security policies. Any personal information you provide on linked pages or other sites is subject to that third party’s privacy policy. We strongly encourage you to review these policies at any site you visit. This Policy does not apply to such linked pages or other sites, and we are not responsible for the content or practices of any linked websites which are provided solely for your convenience.

Children’s Online Privacy Protection

The Website and Products are not intended for use by children under 18 years of age. We do not knowingly collect or use any personal information from any children under 13 years of age. If we become aware that we have unknowingly collected personal information from a child under the age of 13, we will make commercially reasonably efforts to delete such personal information from our database.

Limits of our Policy

This privacy policy only covers Bioenterprise Corporation’s own collecting and handling of data. While we make effort to only work with partners, affiliates and third-party providers whose privacy policies align with ours, we do not accept responsibility or liability for their respective privacy practices.

Our websites may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites, and cannot accept responsibility or liability for their respective privacy practices. We recommend that you take steps to review all privacy and other terms and policies of any third party.

Changes to this Policy
At our discretion, we may change our privacy policy to reflect current acceptable practices. We will take reasonable steps to let you know about changes via our websites. If you are a registered customer on www.bioenterprise.ca or a subscriber of our email marketing, we will notify you using the contact details saved in your account. Your continued use of our sites after any changes to this policy will be regarded as acceptance of our practices around privacy, personal information and cookies.

Questions or Comments

If you have any questions or comments or wish to make a complaint about this Policy, please feel free to contact us by delivery in person, by courier, or by mail, to us at ATCC, Suite 200, 120 Research Lane, Guelph ON N1O 0B4, or by calling us at 519-821-2960. Or toll free 1-866-464 4524 If you contact us about your personal information, we will respond to your request within a reasonable time and at minimal cost or no cost to you in accordance with applicable laws. Depending on the circumstances and applicable laws, we may refuse to process certain access requests (for example and without limitation, access requests that are unreasonably repetitive or systematic, would be extremely impractical or require disproportionate technical effort).

Effective Date: 2018-04-01