Privacy Policy

DAVE PRIVACY POLICY

Last Updated: December 2024

Inline Corporation (“Inline”, “we” or “us”) is committed to protecting your privacy and safeguarding your personal information. The purpose of this privacy policy is to inform you about how we collect, use and disclose personal information when you interact with our website app.buildwithdave.com and with our products and services offered online through Dave (the “Services”).  This privacy policy relates to all of our activities, unless we have provided you with a separate privacy policy for a particular product, service or activity.

In this Policy, we use the word “Customer” to refer to anyone who has subscribed to or paid for use of our Services. We use the word “you” to refer to any other individual user of our Services, such as an employee  of a Customer,  or an individual browsing or using our Website and web-based resources.

Please review this privacy policy carefully. By submitting your personal information to us, by using our website, or by otherwise accessing or using the Services, you consent to our collecting, using and disclosing your personal information as set out in this privacy policy.

Meaning of Personal Information

“Personal information” means information about an identifiable individual.  This information may include, but is not limited to, your name, mailing address, e-mail address, telephone number and country of residence.

Personal information does not include information where there is no serious possibility that it can be used to identify an individual, whether on its own or in combination with other information, or personal information that has been anonymized or aggregated such as to be considered anonymized information or no longer personal information under applicable laws.

Notice to End Users

If you are a user of one of our Customers, the Customer controls your information processed within the Services, including your contact information, billing details and other records. Please contact the relevant Customer for any questions about your personal information.

Your Consent to Collection, Use and Disclosure

The primary basis on which we collect, use and disclose your personal information is with your consent, unless otherwise permitted or required by law. How we obtain your consent will depend on the circumstances, as well as the sensitivity of the information collected. Subject to applicable laws, your consent may be express or implied, depending on the circumstances and the sensitivity of the personal information in question.  If you choose to provide personal information to us, we assume that you consent to the collection, use and disclosure of your personal information as outlined in this privacy policy.

Typically, we will seek your consent at the time your personal information is collected. Where we want to use your personal information for a purpose not previously identified to you at the time of collection, we will seek your consent prior to our use of such information for this new purpose.

You may withdraw your consent to our collection, use or disclosure of your personal information at any time by contacting us using the contact information within our Website.  However, before we implement the withdrawal of consent, we may require proof of your identity. In some cases, withdrawal of your consent may mean that we will no longer be able to provide certain products or services. Please also note that certain data will remain within the Services for us to fulfill our contractual obligations, even after you withdraw your consent.

If you provide personal information about another individual to us, it is your responsibility to obtain the consent of that individual to enable us to collect such information from you, and to use and disclose his or her information as described in this privacy policy.

Our Collection of Personal Information

How we collect Personal Information

We collect Personal Information from you in the following ways:

• Through your use of the Services, whether directly uploaded and created by you, or automatically collected by us as you use the Services. This information is referred to herein as “Customer Data”.
• Through your engagement with our Website, including information submitted by you within a website form or obtained from us through cookies or similar technologies. This information is collectively referred to as “Website Data”.
• From other users within the Services, with whom you may work with or otherwise have an ongoing professional relationship with.
• From other third party sources, such as our partners and service providers.

Types of Personal Information we collect

We collect the following types of information from you:

• Account and Profile Information: we collect your contact information to facilitate the purchase of our Services and to manage our relationship with you. This includes information such as your name, e-mail address and other contact information.
• Third Party Information from other users: Other Customers may provide information about you when they submit content through the Services. Similarly, your employer may provide your contact and employment information when they add you as a user, or designate you as the billing or technical contact on your organization’s account.
• Information from linked accounts: We may receive information about you when you integrate or link a third-party service with our Services. You may also integrate our Services with other services you use, so as to allow you to access, store, share and edit certain content from a third-party through our Services. The information we receive when you link or integrate our Services with a third-party service depends on the settings, permissions and privacy policy controlled by that third-party service. You should always check the privacy settings and notices in these third-party services to understand what data may be disclosed to us or shared with our Services.
• Usage and Technical Information: We collect usage information relating to your use of the Services and how you interact with our Website. Such information may include your Internet protocol address, information about your device, browser and operating system, how you are using our Services, and the date and time of your visit.
• Payment Information: We collect certain payment and billing information when you register for the Services. For example, we may ask that you designate a billing representative, including name and contact information, upon registration.
• Website Forms: We collect information that you submit to us on our Website, including your name, e-mail address and other contact information.

Cookie Policy

We use “cookies” and enlist third party services which use cookies to track your preferences and activities on our website and within our Services. Cookies are small data files transferred to your computer’s hard-drive by a website. They keep a record of your preferences and login information, making your subsequent visits to the Website and Services more efficient and secure. Cookies may store a variety of information, including the number of times that you access a website, your login information, your device information, IP address, and the number of times that you view a particular page or other item on the Website or Services. The use of cookies is a common practice adopted by most major websites to better serve their users. You have a variety of tools to control the information collected by cookies, web beacons, and similar technologies when you use our Website. For example, you can use controls in your internet browser to limit how the websites you visit are able to use cookies and to withdraw your consent by clearing or blocking cookies. You should note, however, that without cookies some of our website’s functions may not be available.

How We Use Your Personal Information

We may use your personal information and other information that we collect to provide the Services, to comply with our contractual obligations, and to support our legitimate interests in maintaining, improving and advertising the Services. Below are the specific purposes for which we use the information we collect about you.

• to provide you with our Services and to support your use of our Services;
• to contact you in relation to our Services;
• to monitor, maintain, and improve our Services, and to develop new products and services;
• to conduct research and analysis related to our business and Services;
• to respond to inquiries and other requests;
• to collect opinions and comments in regard to our Services;
• to provide you with information that we think may interest you, including marketing communications; and
• to comply with legal and regulatory requirements, where applicable.

We may use your personal information and other information for purposes for which we have obtained your consent, and for such other purposes as may be permitted or required by applicable law.

How We Share Your Personal Information

Sharing with Other users

We make tools that facilitate collaboration between various users and organizations. When you use the Services, we may share information with other Customers and their users.

• For collaboration: You can create content, which may contain information about you or your users, and grant permission to others to see, share, edit, copy, and download that content based on settings you or your administrator (if applicable) select. Some of the collaboration features of the Services display some or all of your profile information to other Service users when you share or interact with specific content.
• Managed accounts and administrators: If you register or access the Services using an email address with a domain that is owned by your employer or organization, certain information about you including your name, profile picture, contact info, content and past use of your account may become accessible to that organization’s administrator and other Service users sharing the same domain. If you are an administrator for a site or group of users within the Services, we may share your contact information with current or past Service users, for the purpose of facilitating Service-related requests.

Sharing with Third Parties

We share your personal information with third party service providers who perform some functionality within the Website and Services on our behalf, such as customer service, technical support, hosting, data storage and processing, and research and analytics. We also share your information with third party service providers who provide products and services that we use to operate our business, such as payment processing, email services, marketing campaigns, employee management, surveys and contests.

If we provide your information to service providers for our provision of the Services, then we require that service providers maintain the confidentiality of your personal information and keep your personal information secure. We also require that they only use your personal information for the limited purposes for which it is provided. When our service providers no longer need your personal information for those limited purposes, we require that they dispose of the personal information. In some circumstances, we may permit our service providers to retain anonymized or statistical information that does not identify you. We do not authorize the service providers to disclose your personal information to unauthorized parties or to use your personal information for their direct marketing purposes.  If you would like more information about our service providers, please contact us using the contact information on our website.

Other Disclosures

Additionally, we may disclose your information when we believe such disclosure is permitted, necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce the terms of the agreements for our products and services; (e) to protect our operations or those of any of our affiliates or subsidiaries; (f) to protect our rights, privacy, safety or property, and/or those of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.  In addition, we may transfer your personal information and other information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, brands, affiliates, subsidiaries or other assets.

If we otherwise intend to disclose your personal information to a third party, we will identify that third party and the purpose for the disclosure, and obtain your consent.

Opting Out of Communications

If you no longer want to receive marketing-related emails from us, you may opt out of receiving marketing-related emails by clicking the “unsubscribe” link at the bottom of any email you receive from us.  You may also opt out by contacting us directly using the contact information on our website.

We will endeavour to respond to your opt-out request promptly, but we ask that you please allow us a reasonable time to process your request.  Please note that if you opt out from receiving marketing-related emails, we may still need to send you communications about your use of our products or services, or other matters.

Retention of Personal Information

We will maintain your personal information for as long as they are needed, or as required by applicable laws, regulations, or government orders. After the relevant amount of time has passed, we will delete your information. The general retention periods for data that we hold are as follows.

• Customer Data: We retain Customer Data for as long as an account is active, and for a reasonable time after account termination. We will retain some of your information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, and to support business operations.
• Services Improvement and Development: Where we retain information for Service improvement and development, we take steps to make that information non-personal, non-identifiable and anonymous. We only use this information to uncover collective insights about the use of our Services, and not to specifically analyze personal characteristics about you.
• Information you share on the Services: If your account is deactivated or disabled, some of your information and the content you have provided will remain in order to allow your team members or other users to make full use of the Services.
• Managed accounts: If the Services are made available to you through an organization (e.g., your employer), we retain your information as long as required by the administrator of your account.
• Marketing information: If you have elected to receive marketing emails from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our Services, such as when you last opened an email from us. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.

Security of Personal Information

We have implemented commercially reasonable physical, organizational, contractual and technological security measures with a view to protecting your personal information from accidental or unlawful destruction, loss or theft, unauthorized access, disclosure, copying, use or modification.  We have taken steps to ensure that the only personnel who are granted access to your personal information are those with a business ‘need-to-know’ or whose duties reasonably require such information.

Despite the measures outlined above, no method of information transmission or information storage is 100% secure or error-free, so we unfortunately cannot guarantee absolute security.  In the case of a breach of security safeguards, we will act promptly to mitigate the risks and to inform you where there is a real risk of significant harm, or as otherwise required by law.

You are responsible for maintaining the secrecy of your identification, passwords and/or any personal information in your possession for the use of our website and/or the Services. Always be careful and responsible regarding your personal information. We are not responsible for, and cannot control, the use by others of any information which you provide to them and you should use caution in selecting the personal information you provide to others through our website or the Services. Similarly, we cannot assume any responsibility for the content of any personal information or other information which you receive from other users through our website or the Services. We cannot guarantee, or assume any responsibility for verifying, the accuracy of the personal information or other information provided by any third party.

If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any information that you provided to us has been compromised), please contact us immediately using the contact information on our website.

Your Rights Regarding Your Personal Information

Individuals have a number of rights concerning their personal information under global privacy laws. You may make a written request to access, correct or delete any personal information about you that we have collected, used or disclosed, and we will provide you with any such personal information to the extent required by law. You may also challenge the accuracy or completeness of your personal information in our records. If you successfully demonstrate that your personal information in our records is inaccurate or incomplete, we will amend the personal information as required. If you provided personal information to a Customer and believe it is being processed by us on behalf of that Customer, please make any requests or queries regarding that personal data to the Customer directly.

Where applicable, you may be entitled to additional rights, including: (i) the right to withdraw consent to processing; (ii) the right to object to unlawful data processing, under certain conditions; (iii) the right to erasure of personal information about you, under certain conditions; (iv) the right to demand that we restrict processing of your personal information, under certain conditions, if you believe we have exceeded the legitimate basis for processing, processing is no longer necessary, or believe your personal information is inaccurate; (v) the right to data portability of personal information concerning you that you provided us in a structured, commonly used, and machine-readable format, under certain conditions; (vi) the right to object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you, under certain conditions.

Please note that such rights are not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal data that we hold about you. In the event that we cannot accommodate your request, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

When you exercise your right to deletion of your personal information, we will delete your personal information, subject to some instances where your personal information will be maintained for us to fulfill our obligations under contract to our Customers. This information includes historical posts and content contained within Customer Data.

You also have the right to lodge a complaint with the relevant data protection or privacy authority, such as the Office of the Privacy Commissioner.

We may require that you provide sufficient identification to fulfill your request to access or correct your personal information.  Any such identifying information will be used only for this purpose. We will not charge you any fees to access your personal information in our records without first providing you with an estimate of the approximate fees, if any.

International Transfer and Storage of Information

Personal information may be processed in any country where we have facilities or in which we engage third party service providers to fulfil the purpose for which we collected the personal information. As a result, your personal information may be transferred to countries outside your country of residence, which may have different data protection rules than in your country.  While such information is outside of your country, it is subject to the laws of the country in which it is located, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country.

Our practices regarding your personal information will at all times continue to be governed by this privacy policy and we will continue to comply with all applicable legal requirements. For more information about our policies and practices regarding transfers to other countries, contact us using the contact information in the “How to Contact Us” section below.

Third Party Websites and Services

This privacy policy applies only to our products and services. This privacy policy does not extend to any websites or products or services provided by third parties. We do not assume responsibility for the privacy practices of such third parties, and we encourage you to review all third party privacy policies prior to using third party websites or products or services.

Children’s Information

Our website is not intended for children under the age of 16. Children under the age of 16 should not use our website. If we learn that we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16 without the consent of their parent or legal guardian, please contact us per the “contact us” section below.

Privacy Policy Updates

This privacy policy is current as of the “updated” date which appears at the top of this page. We may modify this privacy policy from time to time.  When changes are made to this privacy policy they will become immediately effective when published in a revised privacy policy posted on our website, unless otherwise noted.  We may also communicate the changes through our Services or by other means. By submitting your personal information to us, by registering for or using any of the Services we offer, by using our Website, or by voluntarily interacting with us after we publish or communicate a notice about the changes to this privacy policy, you consent to our collecting, using and disclosing your personal information as set out in the revised privacy policy.

Contacting Inline

All comments, questions, concerns or complaints regarding your personal information or our privacy practices should be sent to our Privacy Officer at the following email address: privacy@inlinecorp.ca.