This policy is concerned with the protection of your personal information only. Personal information includes any data that can be used to identify you as an individual, including your name, income, personal opinion, interests, home contact information, identification numbers, user IDs, passwords, ethnic origin, and age. Under Canadian law, in a business context, personal information does not include the name, job title, business address, or business telephone number of any employee in an organization.
This policy describes the following practices:
- Collecting information
- Sharing your personal information
- Maintaining your personal information
- GDPR Compliance
- Your Rights
NOTE: Palette products are not intended to be sold to children under the age of 18. We do not knowingly collect or maintain any personal information or non-personally-identifiable information from anyone under the age of 18 nor is any part of our website directed to children under the age of 18. We will not accept product orders from individuals that we know to be children and will remove and/or delete any personal information we believe was submitted by any child under the age of 18.
We collect information about you in the following ways:
As part of your purchase of Palette's products and/or services
We will require your name, address, telephone number, certain financial account or credit card information, and potentially other information of which we will inform you in advance, for billing, shipping and payment purposes. This information is kept confidential and stored securely by Palette and/or its payment provider.
Automatically by Palette’s software and services
Palette’s software and services may contain features that automatically collect information from users, such as usage statistics and other tracking information. Although this information will not identify you personally, it nevertheless provides certain information about you, and we therefore treat it as personal information. Additionally, use of Palette’s website and/or products may result in the collection of technical information such as your computer's IP address, operating system, browser name/version, the referring web page, requested page, date/time, data related to software applications used with Palette’s products, and sometimes a "cookie" (which can be disabled using your browser preferences); such information is used to help us understand the overall usage pattern of our website and products.
As part of your use of Palette's website
You may have the ability to post information on Palette’s website, such as comments and opinions. Please be advised that any personal information that you voluntarily post to any public forum or to any area where third parties may legally access it, will NOT be considered confidential in any way, and Palette will not have any obligation to protect it in a secured system or obtain your consent to its disclosure, as you will have made the decision to publicly post it. However, at your request, Palette will be happy to change it, remove it, or restrict access to it (subject to technical feasibility) in order to protect the integrity of the personal information.
You contact Palette directly
Customers and business partners often contact us directly. When you contact any Palette employee by telephone, e-mail, in person, or through our website, you will be asked to provide consent to the collection of personal information if your personal information will help us deliver the information, products, or services you require.
You respond to communcations from Palette
From time to time, Palette may invite you to provide us with information for specific purposes. We may ask for this information through feedback features on our website or software; we may send out e-mail inviting feedback or offering products and services; or we may ask you for information concerning support of our products or services. Your response to these communications may require you to submit personal information and opinions.
Your information is obtained through a third party
Occasionally, Palette will obtain information about you from third parties, such as mailing list providers, third party service providers, ISPs, or third party application or account providers. Third-party providers are responsible for obtaining consent for the release of personal information to us from those individuals identified on mailing lists, surveys, or through other collection methods.
Third party collection of your information
Sharing your personal information
Subject to any exceptions stated above in the collection of information section, should Palette collect any of your personal information, we will follow these practices regarding the distribution of that information.
Your personal information is protected
Palette uses reasonable precautions to protect your personal information and store it securely. Access to your personal information is restricted to those persons who need it, and Palette takes reasonable steps to prevent the unauthorized use or disclosure of your personal information.
Palette only uses and discloses your personal information if it helps us facilitate your needs, improve our products and services, meet legal and regulatory requirements, or — to the limited extent possible — manage our internal business operations. Additionally, if there are any disclosure or use restrictions in your consent to the collection of your personal information, Palette will abide by those restrictions (subject to the consent exceptions listed below). For example, your credit card or financial information will only be used to bill you for the products and services that you have ordered and/or authorized, as applicable.
Palette may combine your information with other information into an aggregate form, so your information no longer personally identifies you. We may then disclose the aggregate information to third parties, so they can obtain an overall picture of Palette’s products, services, customer sectors and/or usage patterns.
We only share your information with your consent
Palette provides your information to third parties only for purposes to which you have consented, and we require such third parties to keep your information confidential.
In a few situations, Palette may be required to disclose your information without your prior consent. For example, Palette may disclose your information if we are required to do so by law, or if we believe in good faith that such disclosure is necessary to:
- comply with law or legal process
- protect and defend our rights and property, or the rights and property of a third party
- protect against misuse or unauthorized use of any of Palette’s products, services, or other proprietary materials
- protect the personal safety of any person
Palette will always try to provide you with prior notice of such disclosure; however, such notice may not always be possible or reasonable given the circumstances.
Additionally, the nature of Palette’s products provided may require the use of certain information to aid in interoperability with third party products and services. Your personal information will only be used to the limited extent necessary to facilitate such interoperability, and may include the following uses:
- to allow third party suppliers, vendors, contractors and other parties to provide products and services to us or to you, or to act on our behalf (this may include, without limitation, our authorization of such third parties to email our users regarding updates, surveys and other inquiries regarding their experience with our products); and
- to allow for audits and surveys to, among other things, validate the size and composition of the users of Palette’s products and services, and understand their experience with Palette’s products.
Maintaining your personal information
Palette has established the following practices regarding the maintenance of your personal information.
You can request access to your personal information at any time
If, for any reason, you wish to review your personal information that Palette has in its possession, you can contact our Privacy Officer, who will be pleased to provide you with all your personal information that Palette has on file.
You can request changes to your personal information at any time
Sometimes, it will be necessary for you to update your personal information Palette has on file; for instance, up-to-date information is required if you wish to continue to obtain notifications of product recalls or warranty changes. If you wish to make any changes or corrections to your personal information that cannot be done yourself through your personal settings, please contact our Privacy Officer who will implement the changes. This will help us ensure our records are always up-to-date.
You can opt out of communications at any time
Additionally, you always have the choice of whether you wish to receive information – such as e-mail updates – from Palette. In some cases, you may do so simply by changing the preferences in the software application through which Palette provides the services.
If you do choose to opt out of communications respecting products and services provided by Palette, you may not obtain all the benefits we could otherwise provide, such as updates or warnings. Palette will not have any liability to you for your loss of those benefits or any negative effects respecting your use of Palette’s products or services.
You can request that your personal information be destroyed at any time
A situation may arise where you desire to have all of your personal information that is contained in Palette’s records deleted or destroyed. If this is what you wish, please contact our Privacy Officer, who will take care of removing your personal information from all of Palette’s records. However, there may be situations where we are obligated to retain one archival copy of your information to allow us to comply with laws or respond to legal processes. We will inform you of all such situations, and will only use your retained personal information to the limited extent necessary to comply with such laws or respond to legal processes.
The GDPR is a EU data privacy law that will be in effect from May 25, 2018. Palette is GDPR compliant and we allow our customers to control their data.
Under GDPR, it is necessary for us to provide our customers with the following information.
Information we collect:
- Logging Data: As most websites and services delivered over the internet, our servers collect information when you access/use Palette Gear or PaletteApp and record it in the form of log files. The logged data may include your IP address, the date and time the services were used, information about system configuration and plug-ins installed, system preferences and cookie data.
- Device information: PaletteApp collects information about devices accessing the services provided by Palette. The information collected may include the type of the device, the operating system used, device settings, application IDs, unique device identifiers and crash logs.
How we use the above information:
- To provide, update, maintain and protect our Services, Websites and business. This includes use of other Information to support providing of the Services under a Customer Agreement, prevent or address service errors, security or technical issues, analyze and monitor usage, trends and other activities at an Authorized User’s request.
- As required by applicable law, legal process or regulation.
- To communicate with you by responding to your requests, comments and questions. If you contact us, we may use your information to respond.
- To develop, troubleshoot and provide solutions to your requests, and additional features. We strive to constantly improve Palette based on customer feedback. For example, we may consult device usage logs to troubleshoot a reported error.
- We may send you technical, administrative emails and other types of communication as part of our services. We may contact you to inform you about changes to our services and service-related notices, which you may opt-out of. Additionally, we may periodically send emails about new product features and promotions, which you may opt-out of.
Individuals located in the European Economic Area have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, you may have the right to request access to information, as well as seek to update, delete or correct the information.
Opt-out from data collectionUnder the GDPR, you have the right to opt-out from data collection and you can do this by sending an email to our support team, with your registered e-mail ID.
Contacting our Privacy Officer
Ryan Van Stralen